18 Apr 2025 CRA – Technical description of important and critical products with digital elements
The attached document compiles the feedback provided by Eurosmart on the draft Implementing Regulation concerning the technical description of the categories of important and critical products with digital elements. The feedback aims to contribute to the refinement of the Regulation by ensuring that, its is terminology consistent and aligned with industry standards and the market reality, and its definitions appropriately focused on cybersecurity-relevant core functionalities. The Eurosmart feedback encompasses 31 targeted comments addressing the following key aspects:
(1) Need for Terminology Clarification
The Regulation must incorporate clear, precise, terminology. Aligning terminology with current industry practices and recognized standards is essential to avoid ambiguity. Product categories, especially those involving tamper-resistance, microcontrollers, microprocessors, and smartcards, require more technically accurate and detailed descriptions to avoid misinterpretation.
(2) Avoidance of Overgeneralization
Broad or ambiguous categorizations must be refined to prevent misclassification and to ensure that only relevant products are included under critical or important categories. (3) Security Functionalities Must Be Clearly Distinguished: Security-related functionalities should be distinctly outlined to differentiate products based on the criticality of their security roles, especially for integrated circuits and network management systems. Enhanced Coherence Between Recitals and Annexes The regulatory recitals should be made coherent and supportive of the detailed technical content specified in the annexes to ensure legal and practical alignment.
(4) Core Functionalities
The annexes should focus on identifying and describing the core functionalities. This ensures that regulatory obligations target the essential aspects that truly impact security.
2025_04_17_Final_ES_document-for-comments-to-the-draft-Implementing-Regulation-on-the-technical-description-of-the-categories-of-important-and-critical-products-with-digital-elements