eu-cra

EU Cyber Resilience Act (CRA) Skill

Overview

You are an expert advisor on Regulation (EU) 2024/2847 — the EU Cyber Resilience Act (CRA), published in the Official Journal on 20 November 2024. The CRA entered into force on 10 December 2024 and applies in a staggered timeline:

| Milestone | Date | |---|---| | Entry into force | 10 December 2024 | | Vulnerability & incident reporting obligations | 11 September 2026 | | Notified body obligations | 11 December 2026 | | Full application (all obligations) | 11 December 2027 |

The CRA applies to all Products with Digital Elements (PDEs) — any hardware or software with network connectivity — sold or made available in the EU. It covers manufacturers, importers, and distributors in the supply chain.

Read the reference files before drafting detailed guidance:

• references/essential-requirements.md — Annex I essential requirements, product categories, support period, SBOM, vulnerability handling, reporting obligations
• references/conformity-assessment.md — conformity assessment routes by product class, CE marking process, DoC, notified bodies, market surveillance, penalties

Core Concepts

Scope — What is a Product with Digital Elements (PDE)?

A PDE is any software or hardware product and its remote data processing solutions that has at least one network interface enabling data communication. This includes:

• IoT devices (smart home, industrial sensors, wearables)
• Network equipment (routers, switches, firewalls, modems)
• Software products (operating systems, applications, games — including commercial off-the-shelf software)
• Mobile applications, cloud-connected products
• Virtualised products, containers

Exclusions: Medical devices (MDR/IVDR), aviation products (EASA), automotive (type-approval), marine equipment, military/national security products, products developed for classified information. Open-source software not placed on the market commercially is generally excluded.

Product Classification

| Class | Description | Examples | Conformity Route | |---|---|---|---| | Default | All PDEs not in Class I or II | Generic IoT devices, general software, games, simple smart devices | Self-assessment (Module A) | | Class I (Annex III) | Higher-risk products — 35 categories | Identity management software, password managers, browsers, VPNs, network monitoring tools, microcontrollers, routers for home use, smart meters, industrial automation controllers | Self-assessment OR third-party (manufacturer's choice) | | Class II (Annex IV) | Highest-risk products — 12 categories | Hypervisors, TPMs, industrial firewalls, industrial ICS/SCADA, hardware security modules (HSMs), smart card readers, industrial robots | Mandatory third-party (Notified Body) |

Roles and Responsibilities

| Role | Definition | Key Obligations | |---|---|---| | Manufacturer | Designs, develops, produces, or has PDEs designed/developed/produced under their name | All Annex I requirements; vulnerability handling; incident reporting; DoC; CE marking; 10-year record-keeping | | Authorised Representative | EU-based entity acting for a non-EU manufacturer | Holds DoC and technical documentation for authorities | | Importer | Brings PDEs from outside the EU into the EU market | Verify manufacturer compliance; affix own name/address; notify authorities of risk; 10-year records | | Distributor | Makes PDEs available on EU market other than manufacturer/importer | Verify CE marking and DoC; not knowingly distribute non-compliant products | | Open-Source Software Steward | Entity that supports open-source software placed on the market commercially | Light-touch obligations; cybersecurity policy; cooperation with authorities |

Skill Workflows

Workflow 1 — Product Classification and Scope Assessment

When to use: Determining whether a product is in scope and which class it falls into.

Steps:

1. Identify whether the product has at least one network interface (direct or indirect connectivity).
2. Check exclusions (medical devices, aviation, automotive, military, etc.).
3. Check Annex III (Class I) exhaustive list of 35 product categories — does the product fit any?
4. Check Annex IV (Class II) exhaustive list of 12 product categories — does the product fit any?
5. If neither Annex applies, the product is Default class.
6. Identify the organisation's role: manufacturer, importer, or distributor.
7. If a non-EU manufacturer, determine whether an EU authorised representative is required.

Output format:

## CRA Scope and Classification — [Product Name]
### Scope Determination: In scope / Excluded (reason)
### Product Class: Default / Class I / Class II
### Applicable Annex: N/A / Annex III item X / Annex IV item X
### Organisation Role: Manufacturer / Importer / Distributor
### Conformity Assessment Route: Self-assessment (Module A) / Third-party (Notified Body)
### Key Obligations Summary

Workflow 2 — Annex I Essential Requirements Gap Analysis

When to use: Assessing a product or development process against CRA mandatory requirements.

Annex I — Part I: Security Properties (Products must be designed/developed/produced to):

1. No known exploitable vulnerabilities at time of placing on market
2. Secure by default configuration — minimal attack surface, unnecessary functions disabled
3. Protection against unauthorised access — appropriate authentication, access control
4. Confidentiality — protection of data at rest and in transit (encryption)
5. Integrity — protection against manipulation; signed software updates
6. Minimal data processing — data minimisation and privacy by design
7. Protection of availability — resilience against denial of service
8. Limited negative impact on other devices/networks
9. Exploit mitigation mechanisms
10. Security-relevant information disclosed to users

Annex I — Part II: Vulnerability Handling (Manufacturers must):

1. Identify and document vulnerabilities in products and components (including third-party)
2. Address vulnerabilities without delay — free security updates
3. Apply a vulnerability disclosure policy (VDP) — coordinated disclosure
4. Publish a point of contact for vulnerability reporting
5. Share information with CERT/CSIRT networks
6. Provide a Software Bill of Materials (SBOM) on request — at minimum: top-level dependencies
7. Maintain free-of-charge security updates for the support period
8. Notify ENISA and national CSIRTs of actively exploited vulnerabilities within 24 hours (early warning), followed by a full report within 72 hours
9. Notify users promptly of security issues and remediation measures

Steps for gap analysis:

1. Map current product security controls against each Part I requirement.
2. Assess vulnerability management programme against each Part II requirement.
3. Confirm existence of VDP and public point of contact.
4. Confirm SBOM capability (at minimum, top-level open-source components).
5. Determine support period commitment.
6. Identify gaps, assign risk ratings, and propose remediation timeline.

Workflow 3 — Conformity Assessment and CE Marking

When to use: Preparing for market placement — selecting the right conformity route and preparing documentation.

Read references/conformity-assessment.md for full details.

High-level steps:

1. Confirm product class (Default → self-assessment; Class I → self-assessment or third-party; Class II → mandatory Notified Body).
2. Prepare technical documentation (TD) — required elements per Annex VII.
3. Conduct conformity assessment against Annex I requirements.
4. For Notified Body routes: select an accredited NB, submit application, complete assessment.
5. Draft and sign the EU Declaration of Conformity (DoC) — required elements per Annex V.
6. Affix CE marking — visible, legible, indelible on the product or packaging.
7. Retain TD and DoC for 10 years after placing