The Cyber Resilience Act, or CRA, introduces a significant structural change in how Europe handles the cybersecurity of products that include digital elements. According to the CRA, a “product with digital elements” is any software or hardware, including its remote component, that is designed to connect directly or indirectly to a network or that depends on such connectivity to function.

The main objective of this change is to ensure that hardware, software, and connected infrastructures function securely throughout their entire life cycle. This regulation directly impacts manufacturers, distributors, and technology service providers seeking to sell in the European market. Therefore, a thorough understanding of product classification and the different levels of assessment is key to achieving compliance by 2027.

CRA groups products into three main categories:

Standard: these usually have low risks and do not require evaluation by an independent third party, also known as self-declaration by the manufacturer.

Important: these are divided into two classes, with Class I requiring the intervention of a Notified Body only when a harmonized standard has been applied, while Class II always requires evaluation by a Notified Body.

Critical: these are required to obtain the European Cybersecurity Certificate (EUCC).

Relevance of CRA in the physical security sector.

The European Commission recently published Implementing Regulation (EU) 2025/2392 on the technical description of important and critical product categories, which includes in Class I Important products those used to protect the physical security of consumers in a residential environment, such as alarm systems and security cameras. Likewise, access control systems, including authentication readers, biometric readers, and their management programs, are also declared in the same Important - Class I category.

This means that the assessment methods available for intrusion and access control products are:

a)           Internal control procedure (self-declaration) under one of the following two conditions:

•    Full application of existing harmonized standards.

•    EUCC certification with at least a “substantial” level of assurance.

b)    EU Type Examination certification by a Notified Body followed by internal production control

c)    Full quality assurance assessed by a Notified Body

Key Dates.

The regulatory transition will take place in defined phases, with specific milestones that directly affect product. Understanding these key dates is essential to anticipate compliance obligations, make timely technical decisions, and avoid disruptions.

 

Proper product classification under the CRA requires analyzing connectivity, system role, exposure to threats, and the potential impact of failure. Many organizations rely on external expertise to streamline this process and select the most appropriate compliance pathway. Anticipating CRA requirements not only reduces regulatory risk but also delivers competitive advantages by lowering certification costs, strengthening cybersecurity, accelerating market access, and building trust with customers and partners. In this context, products with digital elements (including standalone software, computer programs, and electronic equipment capable of processing, storing, or transmitting data) must be assessed with a lifecycle-focused security approach to ensure long-term compliance and business value.