Cybersecurity Becomes a CE-Marking Requirement

One of the most significant EU regulatory developments for electronics manufacturers is the EU Cyber Resilience Act (CRA).

For the first time, cybersecurity will be treated as a core product compliance issue — not just an IT or post-market concern.

From 11 December 2027, products with digital elements (including connected devices, embedded software, and standalone software) will only be able to carry the CE mark if they meet CRA requirements. This means cybersecurity must be built into product design from the outset, rather than addressed reactively.

What the Cyber Resilience Act Will Require

Manufacturers will need to demonstrate that products:

• Are designed and developed with security by design and by default

• Undergo cybersecurity risk assessments

• Include processes for vulnerability handling, patching, and updates

• Provide security support for a defined lifecycle

• Report actively exploited vulnerabilities to EU authorities

These obligations apply across the entire product lifecycle — from development to post-market support — and will require closer collaboration between engineering, regulatory, and security teams.

Documentation and Accountability Are Expanding

The CRA also strengthens documentation obligations. Technical files will need to cover not only safety and EMC compliance, but also cybersecurity controls, risk management, and vulnerability processes. As with existing CE requirements, manufacturers must retain documentation for at least 10 years and be ready to provide it to authorities on request.

For non-EU manufacturers, the role of EU-based economic operators (authorised representatives, importers, distributors) will become even more critical.

Why This Matters Now

Although CRA obligations apply from 2027, product development cycles mean 2025–2026 is the critical preparation window. Products designed today may still be on the market when the CRA becomes enforceable, creating a real risk of non-compliance if cybersecurity requirements are not addressed early.

At the same time, the EU is signalling a broader shift: digital resilience, lifecycle accountability, and transparency are becoming standard expectations for product safety.

For electrical and electronic products, CE marking is no longer just about electrical safety and EMC. It is evolving into a multi-disciplinary compliance mark that will soon encompass cybersecurity, software governance, and long-term product support.

Manufacturers that start integrating CRA requirements now will be better positioned to avoid disruption, enforcement action, or costly redesigns later.