No. 71: Commission Guidance on the CRA - Placing on the Market
The CRA guidance treats placing on the market differently for standalone software and embedded systems. Longer support periods and workarounds cause higher costs for machine and device manufacturers. It would be simple to treat all products the same.
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Legal Disclaimers as CRA Mitigations
A device violates essential CRA requirements. Although simple state-of-the-art security measures are available, the manufacturer mitigates the violations with legal disclaimers. This goes against the intention of the CRA: improving cybersecurity in real life and not just on paper.
CRA Classification of Embedded Devices: Examples
Per definition, embedded devices are products with digital elements and, hence, must comply with the CRA. I'll give examples whether to classify devices as default, important or critical. The classification decides how expensive CRA compliance is. So, we better get it right.