
The Cyber Resilience Act: Practical Steps and Resources for Manufacturing SMEs — An interview with a MANTRA Expert
As digital products become increasingly connected, cybersecurity is no longer optional, it is a business necessity. The Cyber Resilience Act (CRA), Regulation (EU) 2024/2847, establishes common cybersecurity requirements for products with digital elements across the European Union. By introducing security-by-design principles, vulnerability management obligations, and greater transparency for users, the CRA aims to strengthen the resilience of the EU’s digital ecosystem. While the Regulation will become fully applicable from 11 December 2027, key obligations start earlier, making it essential for manufacturing SMEs to begin preparing now. To help businesses better understand the new requirements, MANTRA has gathered insights from cybersecurity experts across Europe. Acknowledgements: MANTRA would like to thank SECURE – Cyber Resilience for SMEs for contributing their expertise and practical insights to this article. Their perspectives help clarify the implications of the Cyber Resilience Act for manufacturing SMEs and provide concrete guidance on how organisations can begin their compliance journey The Cyber Resilience Act is reshaping the way digital products are designed and managed. What should manufacturing SMEs know about the regulation, and why is it important to start preparing now? The key message is that the Cyber Resilience Act turns cybersecurity from a voluntary good practice into a legal product requirement. The CRA applies to a wide range of hardware and software made available on the European market. Manufacturing SMEs should therefore not assume that it concerns only software companies. Connected machinery, smart sensors, control systems and other products containing digital components may also fall within its scope. Manufacturers will need to manage cybersecurity throughout the product’s lifecycle. In practice, this means assessing cyber risks, designing products securely, controlling vulnerabilities in components and software libraries, providing security updates, handling vulnerability reports and maintaining the necessary technical documentation. Before placing a product on the market, manufacturers must also demonstrate conformity with the CRA and apply the CE marking. The applicable assessment procedure will depend on the type and risk category of the product. Preparation is now urgent. From 11 September 2026, manufacturers must report actively exploited vulnerabilities and serious security incidents. An initial warning may be required within 24 hours and a more detailed notification within 72 hours. The main product-security and conformity obligations will apply from 11 December 2027. European Commission – CRA reporting obligations For many SMEs, compliance will require changes to product development, supplier agreements, update mechanisms, documentation and incident-response processes. These changes cannot realistically be introduced just before the deadline. Companies should start by identifying which products are covered, clarifying their role in the supply chain, assigning internal responsibility and comparing their current practices with the CRA requirements. The CRA should not be approached as a one-off certification exercise. It requires manufacturers to remain responsible for the cybersecurity of their products after they have been sold. Starting early reduces compliance costs, limits last-minute redesigns and helps ensure continued access to the European market. What are the biggest challenges or misconceptions that manufacturing SMEs face when approaching CRA compliance? The biggest challenge is that many manufacturing SMEs still view the CRA as an IT or administrative compliance exercise. In reality, it affects product design, engineering, procurement, after-sales support and management responsibility. A first misconception is: “We manufacture machines, not software.” The CRA covers hardware and software products with digital elements, including connected machinery, sensors, controllers, embedded software and components sold separately. A traditional manufacturer may therefore fall within scope even if software is only one part of its product. A second misconception is that good organisational cybersecurity—or compliance with NIS2 or ISO 27001—automatically means CRA compliance. These measures can help, but the CRA focuses specifically on the security of the product. The manufacturer must assess product-related cyber risks and demonstrate how these risks are addressed. A third challenge is supply-chain visibility. Manufacturers often depend on third-party software, chips, libraries and connected services without having sufficient information about their vulnerabilities or update policies. Outsourcing a component does not remove the manufacturer’s responsibility for the security of the final product. Another common mistake is treating compliance as a one-off test before placing the product on the market. The CRA requires security throughout the product lifecycle. Manufacturers must be able to receive vulnerability reports, provide security updates, manage incidents and support the product for the declared support period. There is also uncertainty about conformity assessment. Not every product automatically requires expensive third-party certification; the applicable procedure depends on the product’s classification and risk profile. However, every manufacturer will need adequate risk assessments, technical documentation and evidence of compliance. Finally, many SMEs are waiting for all standards and guidance to be finalised. That is risky. They can already take “no-regret” steps: identify products in scope, map digital components and suppliers, assign responsibilities, introduce secure development practices and establish vulnerability and update processes. These foundations take time and will be necessary regardless of the final technical standards. Many SMEs believe compliance is expensive and complex. What free or accessible tools, training resources, standards, or support initiatives already exist to help them? The cost concern is understandable, but SMEs do not need to begin with an expensive compliance platform or consultancy project. A growing range of free and accessible resources is already available. In Belgium, the CCB provides CRA information in Dutch, French and German. Through the EU-funded SECURE project, the CCB has also developed practical resources for SMEs: a beginner-friendly “CRA 101” guide, technical guidance on the essential cybersecurity requirements, a methodological compliance-assessment framework containing checklists, examples and references to useful tools, and a CRA Maturity Score tool to help mSMEs assess where they currently stand in terms of compliance and what gaps need closing. Additionally, Trainings are freely available and being produced on a rolling basis, and through SECURE, European mSMEs can receive funding to support their CRA compliance. At European level, the European Commission provides FAQs and practical guidance explaining issues such as product scope, risk assessment, support periods, reporting and substantial modifications. These should be the starting point for interpreting the regulation. ENISA offers particularly useful free resources, for example: The Secure by Design and Default Playbook translates product-security principles into concrete engineering actions and examples of supporting evidence. ENISA also provides instructions and FAQs for the CRA Single Reporting Platform, which manufacturers will use to report actively exploited vulnerabilities and serious incidents. Several EU-funded initiatives provide or are developing open-source tools, training, templates and compliance-assessment support. These can help with subjects such as product-risk assessments, technical documentation, software bills of materials, vulnerability management and security testing. SMEs should check the project portals regularly, as available tools, training sessions and funding opportunities evolve. Existing standards such as IEC 62443 for industrial systems and ETSI EN 303 645 for consumer IoT can also provide useful technical building blocks. However, using a standard does not automatically prove CRA compliance. Only harmonised standards formally recognised under the CRA can provide a presumption of conformity for the requirements they cover. The CCB’s CyberFundamentals framework and Safeonweb@work resources can help SMEs strengthen their general organisational cybersecurity. They are valuable foundations, but they should not be confused with a complete CRA product-compliance assessment. Our advice is therefore to use the free resources first to determine scope, assess gaps and create an implementation roadmap. Specialist support can then be reserved for areas where it adds real value, such as product classification, conformity assessment or specialised security testing. If you could recommend just three practical actions that an SME should take today to begin its CRA journey, what would they be? 1.Identify your products in scope and assign ownership Create a simple register of the products and versions you place on the EU market, including their software, connected functions and third-party components. Record your role—manufacturer, importer or distributor—and make an initial assessment of the likely product classification and conformity route. Appoint one responsible CRA coordinator, supported by engineering, quality, procurement and legal staff. 2. Perform a gap assessment on one priority product Select a representative or high-risk product and compare its current design and lifecycle processes with the CRA’s essential cybersecurity requirements. Map its architecture, interfaces, software dependencies, suppliers, update mechanisms and existing security measures. Document the risks, gaps, actions and available evidence. Starting with one product creates a repeatable method that can later be applied across the portfolio. 3. Make vulnerability handling and reporting operational Establish a clear contact point for vulnerability reports and define how the company will monitor, assess, correct and communicate vulnerabilities. Include supplier escalation, security updates, customer communication and regulatory reporting. Test the process using a realistic scenario: could the company identify affected products, take decisions and submit an early warning within 24 hours? This third action is particularly urgent because the CRA reporting obligations apply from 11 September 2026, ahead of the full application of the remaining requirements in December 2027. These actions should produce three tangible results: a product register with clear ownership, a prioritised compliance roadmap and a tested vulnerability-response process. That is a much stronger starting point than collecting legal documents without changing how products are designed and supported. Contributor: Yves Streel SECURE Senior Project Manager NCC-BE department at the Centre for Cybersecurity Belgium





