The CRA is Coming: Why Equipment OEMs Can't Afford to Wait
The clock is ticking for equipment manufacturers. By late 2027, the EU Cyber Resilience Act (CRA) will fundamentally change how Original Equipment Manufacturers (OEMs) bring products to market. If your industrial equipment, control systems, or smart components contain any digital elements, and most do today, the CRA will apply to you.
This isn't just another compliance exercise that can be handled by your legal team. The CRA demands fundamental changes to how you design, manufacture, and support your products throughout their entire lifecycle. And the cost of non-compliance is too high to ignore.
Your Products Are In Scope
Many OEMs assume the CRA only applies to IT products or consumer electronics. This is a dangerous misconception. The regulation covers any product with digital elements that connects directly or indirectly to networks or other devices. This includes:
Industrial Control Systems
- Programmable Logic Controllers (PLCs)
- Human Machine Interfaces (HMIs)
- SCADA systems and components
- Industrial network equipment
Embedded Systems
- Microcontroller-based control units
- Firmware-driven components
- Smart sensors and actuators
- Connected monitoring devices
Smart Equipment Components
- IoT-enabled machinery parts
- Remote diagnostic systems
- Predictive maintenance modules
- Connected power management systems
If your equipment includes software, connects to a network, or communicates with other devices, whether through wired connections, wireless protocols, or internet connectivity, it falls under CRA jurisdiction. Even components that only occasionally connect for updates or diagnostics are covered.
The Real Cost of Non-Compliance
The penalties for CRA violations aren't symbolic. They're designed to ensure compliance. Organizations face fines of up to €15 million or 2.5% of global annual turnover, whichever is higher. But the financial penalties are just the beginning.
Market Exclusion
Non-compliant products cannot be placed on the EU market. This means:
- No sales in the 27 EU member states
- No distribution through EU-based channels
- Potential recalls of non-compliant products already in the field
- Lost revenue from one of the world's largest industrial markets
Competitive Disadvantage
While you're scrambling to achieve compliance, your competitors who started early will already be:
- Marketing their certified, secure products
- Winning contracts that require CRA compliance
- Building trust with customers increasingly concerned about cybersecurity
- Establishing themselves as industry leaders in security
Supply Chain Disruption
Your customers, system integrators, machine builders, plant operators, will demand CRA-compliant components. If you can't provide them, they'll find suppliers who can. This isn't just about losing individual sales; it's about being dropped from approved vendor lists and long-term supply agreements.
Reputational Damage
In an era where cybersecurity breaches make headlines, being found non-compliant with major security regulations damages your brand reputation. The industrial sector has a long memory, and customers won't quickly forget manufacturers who failed to take security seriously.
Security by Design: The Core Requirement
The CRA's most fundamental requirement is security by design: The principle that cybersecurity must be embedded into products from the earliest stages of development, not bolted on as an afterthought.
For OEMs, this means transforming your entire product development process:
Secure Development Lifecycle
You must implement and document secure development practices including:
- Threat modeling during product design
- Secure coding standards and practices
- Security testing throughout development
- Code review processes with security focus
- Secure configuration management
This isn't about adding a security checklist at the end of development. It's about fundamentally rethinking how you build products, with security considerations driving design decisions from day one.
Risk-Based Security Measures
Products must include appropriate cybersecurity features based on the risks they present:
- Secure authentication and authorization mechanisms
- Encrypted communication channels
- Secure boot and firmware verification
- Protection against known vulnerability classes
- Secure update mechanisms
For industrial equipment, this often means retrofitting security features into products originally designed in an era when network connectivity wasn't the norm. This is particularly challenging for OEMs with long product lifecycles.
Vulnerability Management
The CRA requires active vulnerability management throughout the product's entire expected lifetime:
- Continuous monitoring for security vulnerabilities
- Coordinated vulnerability disclosure programs
- Security updates and patches delivered promptly
- Public disclosure of vulnerabilities according to defined timelines
- Incident response procedures for security breaches
For OEMs, this means establishing infrastructure and processes to support products potentially deployed for decades. You can't simply sell equipment and walk away. You must maintain security support for the product's operational life.
Technical Documentation
You must create and maintain comprehensive technical documentation proving:
- How security by design was implemented
- What security features are included
- How security testing was conducted
- What vulnerabilities were found and how they were addressed
- How security updates will be provided
This documentation isn't for your internal use. Tt must be available to authorities conducting conformity assessments.
Critical and Important Products: Enhanced Requirements
If your products are classified as "important" or "critical" under the CRA (many industrial control systems fall into these categories), you face additional requirements:
- Third-party conformity assessment: Independent verification of your security measures
- Enhanced documentation: More detailed technical files and risk assessments
- Stricter reporting timelines: Faster notification of actively exploited vulnerabilities
- Cybersecurity risk assessments: Formal assessment of risks throughout the product lifecycle
These requirements add significant time and cost to product development and market introduction.
The Window for Action is Closing
While full CRA enforcement doesn't begin until late 2027, the time to act is now. Here's why:
Development Cycles: Industrial equipment typically has development cycles of 2-4 years. Products in early design stages now will be launching right as CRA enforcement begins.
Process Changes: Implementing security by design isn't just about adding features: Tt requires fundamental changes to development processes, which take time to establish and mature.
Supply Chain Alignment: Your component suppliers also need to achieve CRA compliance. The sooner you engage with them about requirements, the better positioned you'll be.
Competitive Advantage: Early movers can market their CRA-ready products ahead of the competition, winning customers who are already planning for compliance.
Testing and Certification: For critical products requiring third-party assessment, expect bottlenecks as certification bodies face high demand approaching the deadline.
Your Next Steps
The CRA represents both a significant challenge and an opportunity for equipment OEMs. While compliance requires substantial effort and investment, it also drives you to build more secure, trustworthy products: A competitive advantage in an increasingly connected industrial world.
Immediate Actions
- Identify affected products: Conduct a comprehensive review of your product portfolio to determine which products fall under CRA scope
- Perform gap analysis: Assess current development practices, security features, and documentation against CRA requirements
- Prioritize efforts: Focus first on products launching soonest and those most critical to your business
- Engage stakeholders: Bring together R&D, quality, legal, and product management to coordinate response
Build Your Roadmap
Don't try to solve everything at once. A phased approach with clear milestones is essential. You need a realistic roadmap that accounts for:
- Resource constraints
- Product development schedules
- Supply chain dependencies
- Budget allocation across fiscal years
Get Expert Guidance
Navigating CRA compliance for industrial products requires specialized expertise spanning regulatory requirements, industrial control systems, and cybersecurity best practices. You don't have to figure it all out alone.
Think Ahead specializes in helping equipment OEMs achieve CRA readiness. We understand the unique challenges of industrial products - long lifecycles, safety-critical systems, operational technology constraints, and can help you build a practical compliance roadmap.
Schedule Your Free 30-Minute Consultation
We're offering OEMs a complimentary 30-minute consultation to:
- Assess your CRA compliance readiness
- Identify your highest-priority gaps
- Discuss our Think Ahead solution for continuous compliance monitoring
- Answer your specific questions about CRA and your products
The CRA deadline is fixed, but your path to compliance doesn't have to be painful. Let's talk about how to turn this regulatory requirement into a competitive advantage.
Schedule Your Free Consultation →
Don't wait until your competitors are already certified and you're locked out of the market. The time to act is now.