Free Webinar on 30 April 2025, 11:00 AM CET with Clemens Kressmann
The EU Cyber Resilience Act (CRA) establishes, for the first time, mandatory cybersecurity requirements for all products with digital elements on the European market. For manufacturers of PLCs, gateways and industrial control systems, this fundamentally reshapes the competitive landscape. The central question is no longer whether cybersecurity becomes relevant, but how quickly manufacturers can systematically turn regulatory requirements into differentiation, customer retention and sustainable value creation.
Three Factors Define the Window of Opportunity
The regulatory timeline illustrates why the decisive window for action is now. The CRA entered into force on 10 December 2024. Reporting obligations apply from September 2026. Full application begins in December 2027. Between these milestones lies a strategic window that manufacturers will either seize or lose.
First, the role of cybersecurity is shifting. What previously served as a differentiator is becoming a market access prerequisite. Manufacturers that manage this transition early shorten their time-to-market while competitors are still evaluating conformity assessment pathways.
Second, pressure from the supply chain is intensifying. OEM customers and integrators increasingly demand CRA conformity as a procurement criterion. Manufacturers that can demonstrate compliance gain a measurable trust advantage long before the regulation fully applies.
Third, a new value creation lever is emerging. Security by Design and systematic vulnerability management are not compliance costs. Applied correctly, they strengthen customer retention, reduce market risks and secure revenue sustainably.
The Requirements in Detail
The complexity of the CRA is frequently underestimated. Annex I defines the essential cybersecurity requirements in two categories: 13 requirements for product security and 8 for vulnerability handling. Product classification under Articles 7 and 8 as well as Annexes III and IV determines the conformity assessment pathway, directly influencing the complexity and time required for market authorization.
Additionally, the SBOM requirements under Article 13 establish the operational foundation for scalable vulnerability management and transparency across the supply chain. For manufacturers of industrial automation components, this means every product decision carries regulatory consequences, and every regulatory requirement holds strategic potential.
Why Early Positioning Is Also Risk Mitigation
One aspect receives insufficient attention in the current CRA debate: the operational reality of conformity assessment. The CRA distinguishes between default products, important products (Class I and II) and critical products. Approximately 90 percent of all products fall into the default category and can be declared conformant through manufacturer self-assessment (Module A), without involving an external testing body (BSI, 2025). For manufacturers that develop and document their products in line with CRA requirements early, this creates a significant advantage: the conformity assessment remains internal, predictable and fast.
The situation differs for important products of Class I and II under Annex III and critical products under Annex IV. Class II products, including firewalls for industrial use and tamper-resistant microprocessors, require mandatory third-party assessment by a Notified Body. For Class I products, self-assessment under Module A is possible in principle, but only on the condition that harmonized standards are fully applied. As of April 2026, these standards are not yet available. CEN, CENELEC and ETSI are developing a total of 41 harmonized standards, with full publication not expected until late 2027. Until then, Class I manufacturers must also plan for external third-party assessment.
At the same time, CRA-specific Notified Bodies have not yet been notified. Notification is expected to begin in Q3/Q4 2026. Industry experts estimate 3 to 6 months of lead time per third-party assessment. If thousands of manufacturers simultaneously submit their conformity assessments shortly before December 2027, bottlenecks are likely to cause significant delays and unpredictable costs. For Class I and II products, industry analyses estimate costs of EUR 80,000 to 200,000 per product line, in addition to ongoing costs for vulnerability management.
Manufacturers that begin implementation early avoid this congestion. Those selling default products and developing CRA-compliantly can conduct the entire conformity assessment independently. Those manufacturing Class I or Class II products secure testing capacity early and calculate costs reliably. In both cases, early positioning is not merely a strategic opportunity. It is a necessary risk mitigation measure that, in the worst case, secures market access and, in the best case, shortens time-to-market.
Webinar: From Regulatory Obligation to Strategic Advantage
On 30 April at 11:00 AM CET, Clemens Kressmann provides a strategic assessment of these requirements in a free 60-minute webinar and demonstrates how manufacturers can leverage the CRA as a deliberate opportunity.
In focus:
- CRA timeline and strategic window of opportunity from entry into force through reporting obligations to full application
- The essential cybersecurity requirements from Annex I and their practical implementation in industrial automation
- Product classification as the basis for conformity assessment and a lever for shortening time-to-market
- SBOM requirements as the operational foundation for scalable vulnerability management across the supply chain
- Security by Design and vulnerability management as value creation levers and differentiation factors for OEM customers and integrators
- How regulatory requirements can be systematically converted into differentiation, customer retention and sustainable value creation
Strong Positioning as Competitive Advantage
The CRA affects all manufacturers of connected products on the European market. However, the strategic relevance is not evenly distributed. Four starting positions determine the leverage effect of early positioning:
Component manufacturers and machine builders operate at the intersection of supply chain and end product. Their CRA conformity is becoming a qualification criterion in tenders and procurement processes. Those that deliver early become the preferred partner.
Organizations without a structured security strategy benefit most from a systematic entry point. The CRA provides the framework to establish cybersecurity not as an isolated project but as an integral part of product development.
Manufacturers facing growing customer pressure are already experiencing an increase in CRA-related inquiries within procurement processes. Reactive responses are no longer sufficient. What is needed is a robust strategy that builds trust and strengthens sales.
Teams requiring fast, measurable progress do not need another evaluation cycle but a clear implementation path that delivers visible results within weeks.
Manufacturers seeking to systematically increase their value creation through CRA conformity will find the strategic entry point in this webinar.
Registration
30 April 2025. 11:00 AM CET. 60 Minutes. Free.
