The CRA forces manufacturers to protect their embedded systems properly against cybersecurity threats. Otherwise, they face heavy penalties and sales bans. We provide practical tips, how to perform a risk assessment, which security measures are enough to satisfy the essential product requirements, how to tame the thousands of vulnerabilities, and whether it's worth to make an embedded system comply with the CRA at all.
Instead of fixing hundreds of CVEs, manufacturers can provide enough security measures to make the exploitation unlikely. The decrease of the CVSS metrics is a useful indicator how effective the security measures are. This post is about understanding the CVSS metrics.
From now on, I'll use heat pumps in private homes as the running example for my CRA articles.
WRONG: substantial modification => new placing on the market. Logical somersaults needed to avoid infinite support periods and full conformity assessment for all legacy products. --- RIGHT: substantial modification => update conformity assessment. No trickery needed.
Do suppliers of FOSS components like Qt LGPL, Weston/Wayland, Linux BSPs, containers and OTA update solutions have to perform no, light-touch or full CRA compliance? The answer affects how much due diligence machine and device manufacturers must exercise for these components in their CRA compliance.
The definitions for making available on the market, placing on the market, intended purpose and substantial modification are crucial for understanding the CRA. The CRA, Blue Guide and Commission guidance interpret them differently. I am trying to sort out this mess.
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.
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.
Courts will do it! Cybersecurity experts throw a lot of security measures at the wall and see which ones stick. They seriously suggest that manufacturers must only do a "proper" risk assessment and all is fine. Manufacturers define what "proper" means. Isn't that circular reasoning?
If a machine sold in 2015 receives a feature update in 2028 or later, it must undergo full CRA compliance (Article 69.2). The best bet for the manufacturer might be to argue that the CRA violates legal certainty and non-retroactivity of law - constitutional rights in most EU countries.