No. 72: Commission Guidance on the CRA - Infinite Support Periods
The Commission guidance creates an infinite support period: Substantial modifications imply new placing on market, which restarts the support period over and over again. I refute the first implication with the CRA itself and show how to legally shorten the support period.
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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.
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