The CRA reporting duty has been live since 11 September 2026. The Machinery Regulation does not start until 20 January 2027, and full CRA CE marking until 11 December 2027. Here is what a PLC-controlled crane has to document, which radio remotes lose their presumption of conformity, and what the whole exercise costs per machine.
Since 11 September 2026, anyone manufacturing a crane with a networked controller for the EU market has a legal duty to report actively exploited vulnerabilities inside that crane within 24 hours of learning about them. That clock started six weeks ago. The machinery safety rules most factories are still preparing for do not begin until 20 January 2027. The horizontal cyber rules that turn the whole thing into a CE marking file do not fully apply until 11 December 2027. Three dates, two regulations, one machine.
Most of the buyers we quote in Europe have heard of exactly one of these. Usually the Machinery Regulation, because that is what their notified body asks about. Almost nobody has asked us yet about the CRA reporting duty, and that is the one already running.
Regulation (EU) 2023/1230, the Machinery Regulation, replaces the old Machinery Directive 2006/42/EC and applies to machinery placed on the market from 20 January 2027. It is a safety law that now contains a cybersecurity requirement. Annex III section 1.1.9 is titled "Protection against corruption": connections to other devices must not create hazardous situations, safety-critical hardware and software and data must be protected against accidental or intentional corruption and must be identified, and legitimate or illegitimate interventions must be recorded. Section 1.2.1 covers safety and reliability of control systems.
Regulation (EU) 2024/2847, the Cyber Resilience Act, is a product cybersecurity law. It entered into force on 10 December 2024. Chapter IV on notified bodies has applied since 11 June 2026. The reporting obligations started on 11 September 2026. The main obligations apply from 11 December 2027.
A PLC-controlled overhead crane is a machine under the first and a product with digital elements under the second. The Commission's own CRA FAQ is blunt about what that means. Question 2.4.1 says manufacturers of products that fall under both "should comply with both the essential cybersecurity requirements set out in this Regulation and the essential health and safety requirements set out in Regulation (EU) 2023/1230", and that any synergy "has to be demonstrated by the manufacturer". Question 2.4.3 goes further: conformity assessment under one instrument "cannot automatically be considered as sufficient to also satisfy the procedure that is required to be followed as per the other instrument".
Two files, two declarations, one crane. That is the shape of the problem.
| Item | Machinery Regulation 2023/1230 | Cyber Resilience Act 2024/2847 |
|---|---|---|
| What it is about | Physical safety of the machine, plus protection against corruption of safety functions | Cybersecurity of the digital product across its whole life, including updates |
| Applies to a crane from | 20 January 2027 | 11 December 2027 for main obligations, 11 September 2026 for incident reporting |
| Who assesses | Self-assessment for most cranes, notified body for Annex I listed machinery | Self-assessment by default, third party for "important products" in Annex III |
| Deliverable | Technical file, EU declaration of conformity, CE mark, instructions with residual risks | Technical documentation, EU declaration of conformity, CE mark, SBOM, support period, vulnerability process |
| Ongoing duty | Keep the file 10 years, act on incidents that reveal non-conformity | Handle vulnerabilities for the whole support period, report exploited ones in 24 hours |
This is the part that gets lost in the summaries. The CRA is not one deadline. It is a staircase, and the section that hurts a factory most is the one that is already in force.
| Date | What applies | What it means for a crane maker |
|---|---|---|
| 10 December 2024 | CRA entered into force | Nothing operational, but the design clock starts |
| 1 August 2025 | Radio Equipment Directive cyber requirements (Delegated Regulation 2022/30) | Already hits every radio remote control shipped into the EU |
| 11 June 2026 | CRA Chapter IV, notified bodies | Third-party assessment becomes bookable |
| 11 September 2026 | CRA reporting obligations and the ENISA Single Reporting Platform | Already live. Applies to products already on the EU market, not only new ones |
| 20 January 2027 | Machinery Regulation 2023/1230 | Annex III 1.1.9 and 1.2.1 become part of the CE file |
| 11 December 2027 | CRA main obligations | Full CE marking under the CRA, SBOM, support period declared in the instructions |
| 11 December 2027 | Reporting for open-source software stewards | Relevant only if you maintain a project you also sell commercially |
The Commission's own announcement on 11 September 2026 spelled out the detail that catches people: the reporting obligations apply to all products with digital elements made available in the EU, "including those already on the market". A 2019 crane with a 4G diagnostics gateway that has been sitting in a Dutch plant for seven years is inside that sentence. The obligation attaches to the manufacturer, not to the year of sale.
Two categories, four clocks. An actively exploited vulnerability in your product and a severe incident affecting its security are different triggers, and they end on different deadlines.
| Stage | Deadline | What goes in it |
|---|---|---|
| Early warning | 24 hours from becoming aware | That a suspected exploitable vulnerability or severe incident exists, plus basic facts |
| Full notification | 72 hours | General information on the product, the nature of the exploit or incident, and initial mitigation |
| Final report, exploited vulnerability | 14 days after a corrective measure is available | Root cause, applied fix, affected versions, user actions |
| Final report, severe incident | 1 month from the 72-hour notification | Same shape, plus what was done to stop recurrence |
The filing route is one portal. ENISA built and operates the CRA Single Reporting Platform, operational since 11 September 2026. A manufacturer reports once. The platform routes the notification to the CSIRT of the member state where the manufacturer has its main establishment and, unless exceptional circumstances apply, makes the information available to ENISA at the same time. The receiving CSIRT then shares it with the other national CSIRTs where the product is sold.
There is a narrow door for delay. On 11 December 2025 the Commission adopted a delegated act setting the terms under which a CSIRT may hold back dissemination to other CSIRTs on justified cybersecurity grounds. Assume you will not qualify. Plan as if your customer's national authority learns on the same day you file.
For a factory in Zhejiang with no EU establishment, the practical question is who files. The regulation attaches the duty to the manufacturer, and a distributor or importer cannot absorb it. This is the single point where a European sales partner has to be brought into the conversation early, because the platform needs a named organisation with a working incident process behind it, not a sales office.
More of the bill of materials than most quotations admit. The test is not "does it have a chip", it is whether the item is a software or hardware product that connects, directly or indirectly, to another device or network.
| Component on a standard EOT crane | Product with digital elements? | Why it lands in the file |
|---|---|---|
| PLC / crane controller with Ethernet or fieldbus | Yes | Executes safety logic, connects to the plant network |
| Variable frequency drive with configuration software | Yes | Firmware, parameters that change braking and speed limits |
| HMI panel or touch screen | Yes | Runs an operating system, often with a web server |
| Remote diagnostics gateway, 4G router, VPN box | Yes, and usually an "important product" | VPN gateways and routers are named in Annex III Class I |
| Radio remote transmitter and receiver | Yes, and also radio equipment | Two regimes at once: RED cyber requirements plus CRA |
| Anti-sway or positioning controller | Yes | Firmware that directly commands motion |
| Load cell, load limiter display, overload protection | Yes when it processes and transmits data | A spoofed load signal defeats the machine's own protection |
| Bridge girder, end carriage, drum, hook block, wire rope | No | No software, no connection. Steel stays steel. |
The list matters because the CRA does not ask you to certify each screw. It asks you to know which items are digital, who made them, which version they are on, and how a vulnerability in any of them gets fixed during the support period. That is an inventory problem before it is an engineering problem.
A standard single girder crane with a chain hoist and a pendant control usually carries three or four of these items. Add a remote diagnostics gateway and the count doubles. A hoist and accessory package sold separately brings its own declaration, because the hoist is its own product with digital elements when it ships with an inverter and a control board.
No. The Commission set out the technical descriptions of important products with digital elements in Implementing Regulation (EU) 2025/2392, and cranes are not in it. That is good news, because Class I and Class II products carry heavier conformity assessment routes.
But the components are a different story. The Class I list includes things that appear on crane BOMs every week:
| Class I category in Annex III | Where it shows up on a crane |
|---|---|
| Products with the function of a virtual private network | The remote service tunnel you install so your engineer can log in from Zhejiang |
| Routers, modems intended for connection to the internet, and switches | The 4G router in the cabinet that gives the crane its SIM card |
| Physical and virtual network interfaces | Ethernet, Wi-Fi and fieldbus interface cards and adapters |
| Operating systems | The real-time OS or Windows build inside the HMI panel |
| Identity management and privileged access management | The remote-access account system used by your service team |
| Security information and event management systems | Only if you resell plant-level monitoring with the crane |
Article 7(1) of the CRA protects you from a cascade: integrating a product that has the core functionality of a Class I or Class II category does not in itself drag the host product into those procedures. But you still have to ensure the supplier did its job, and if there is no declaration of conformity and no CE mark for that component, the responsibility for it is yours. Put that in the purchase order, not in a phone call.
Five years is the floor, and for industrial equipment the recital tells you to go further. Recital 60 of the CRA says the support period should be no less than five years unless the product's lifetime is shorter, and adds that products "intended for use in industrial settings, such as industrial control systems, are often in use for significantly longer periods of time".
Read that next to a crane's real service life of 20 to 30 years and the gap is obvious. Nobody expects a 2027 PLC to receive patches in 2052. What the regulation expects is that you say, in writing, when the patches stop.
Annex II requires the end date of the support period to be given to the user together with the product. That single line in the instruction manual is what a maintenance manager will use to plan the retrofit, and it is what a market surveillance officer will read first.
| Crane class and duty | Typical service life | Defensible declared support period |
|---|---|---|
| Light workshop crane, A3-A4, 1-10 t | 15-20 years | 5 years for the digital components, stated as such |
| Production crane, A5-A6, 10-50 t | 20-25 years | 8-10 years, with a documented controller upgrade path |
| Heavy or process crane, A7-A8, 50-100 t | 25-30 years | 10 years, plus a contractual migration window |
| Crane with radio remote only, no network | 15-20 years | Support period set by the radio equipment, often 5-7 years |
Those period ranges are our own planning assumptions from Chinese and European service records, not a published statistic. The five-year floor is law; everything above it is a commercial decision that should be made with the buyer before the order, because it is much cheaper to promise ten years with a controller roadmap than to argue about it in year six.
The technical documentation requirement is the part that turns a factory's existing CE file into a working document. A crane file written for the old Machinery Directive typically contains drawings, calculations, risk assessment, test reports and a declaration. It almost never contains a component inventory with versions.
| Item | What it looks like on a crane | Common gap today |
|---|---|---|
| General description and intended use | Capacity, span, duty class, environment, interfaces | Usually present, rarely mentions the network interface |
| Risk assessment including cyber risk | What happens to motion if a signal is spoofed or replayed | Missing. Safety risk assessment stops at mechanical hazards |
| Software bill of materials | Every third-party library and firmware version in the controller, HMI and gateway | Does not exist. Recital 77 expects one, and does not require it to be public |
| Vulnerability handling process | Who receives a report, who triages it, how a fix reaches a crane in Spain | Missing, and this is the clause a buyer's IT department will test |
| Secure update mechanism | Signed firmware, rollback, and a path that works without an internet connection | Usually a USB stick and an email, undocumented |
| Coordinated disclosure policy and contact | A public security contact, not a sales inbox | Missing, and it is the cheapest item on the list to fix |
Two things are worth saying plainly about the SBOM. First, the regulation does not force you to publish it. Recital 77 says manufacturers "should not be obliged to make the SBOM public". Second, it is useless if it is compiled once. The value is in being able to answer, within a day, whether a library disclosed last week is inside your controller firmware. That is a database, not a PDF.
All three, in different ways, and the importer carries more than most Chinese suppliers assume. Under the CRA the importer is the EU entity that places a product bearing a non-EU manufacturer's name on the market. It has to verify that the manufacturer met the essential cybersecurity requirements and has vulnerability-handling processes in place, that the conformity assessment was carried out, that the technical documentation exists, and that the CE mark is affixed. An importer that does not do this is not a passive channel; it is a liable party.
The manufacturer may appoint an authorised representative inside the Union by written mandate to carry out specified tasks. It is optional, and it is not a substitute for the manufacturer's own obligations, but it is the mechanism that makes a 24-hour reporting duty survivable for a company whose engineers are asleep when Europe is awake.
| Role | Core duty under the CRA | Where it usually breaks |
|---|---|---|
| Manufacturer | Design, conformity assessment, CE, documentation, support period, vulnerability handling, 24-hour reporting | No process that survives a weekend |
| Authorised representative | Tasks listed in a written mandate, typically authority liaison and documentation holding | Mandate signed but no technical capability behind it |
| Importer | Verify compliance, CE, documentation, and the manufacturer's vulnerability process before placing on the market | Treats the crane like any other machine and asks only for a CE certificate |
| Distributor | Check CE and declaration before making the product available, act if it is non-compliant | Stores a PDF, never checks the version |
The penalties explain why importers are starting to ask. Article 64 sets administrative fines of up to EUR 15,000,000 or 2.5 % of total worldwide annual turnover, whichever is higher, for breaching the essential cybersecurity requirements and the manufacturer obligations. Documentation and procedural failures sit at EUR 10,000,000 or 2 %. Supplying incorrect, incomplete or misleading information to a notified body or a market surveillance authority sits at EUR 5,000,000 or 1 %.
| Infringement | Maximum administrative fine |
|---|---|
| Essential cybersecurity requirements, manufacturer obligations | EUR 15,000,000 or 2.5 % of worldwide annual turnover, whichever is higher |
| Importer, distributor and other procedural obligations | EUR 10,000,000 or 2 % of worldwide annual turnover, whichever is higher |
| Incorrect, incomplete or misleading information to authorities | EUR 5,000,000 or 1 % of worldwide annual turnover, whichever is higher |
For a mid-sized crane builder the percentage branch rarely bites. The EUR 15 million branch does not care about your headcount, and being told to withdraw a model from the EU market costs more than any fine.
Industrial control systems are not a theoretical target. The disclosure pipeline alone tells a story: the number of published industrial control advisories keeps rising, and the severity is rising with it.
| Measure | Value | Source |
|---|---|---|
| ICS advisories published in 2025 | 508, covering 2,155 CVEs (first year above 500) | Forescout Research, February 2026, on CISA data |
| Average CVSS of those advisories | 8.07, up 25 % from 6.44 in 2010; 82 % high or critical | Forescout Research, February 2026 |
| Cumulative advisories since 2010 | 3,637 advisories, 12,174 vulnerabilities, 2,783 products, 689 vendors | Forescout Research, February 2026 |
| OT devices containing known exploited vulnerabilities | 12 % of more than 940,000 devices across 270 organisations | Claroty Team82, State of CPS Security 2025 |
| Organisations with such devices exposed to the internet | 40 %, rising to 31 % for the subset where the vulnerability is tied to ransomware | Claroty Team82, State of CPS Security 2025 |
| Ransomware growth in manufacturing, 2024 to 2025 | 61 %, the largest increase of any critical sector | Claroty, 31 October 2025 |
Read the fourth and fifth rows together. Roughly four in ten of the plants surveyed had insecure remote access sitting on assets that already carried a known exploited vulnerability. That is exactly the arrangement created by a diagnostics gateway bolted onto a crane so the factory can help the customer without sending an engineer. The gateway is not the problem. The gateway with a shared password and no update path is.
Radio remote controls reached this party first. Commission Delegated Regulation (EU) 2022/30 made the cybersecurity essential requirements in Article 3(3)(d), (e) and (f) of the Radio Equipment Directive mandatory for listed categories of radio equipment from 1 August 2025. A crane transmitter and receiver pair is radio equipment, so every handheld unit shipped into the EU since that date sits inside it.
The harmonised standards are EN 18031-1:2024 for internet-connected radio equipment and EN 18031-2:2024 for equipment processing personal data. They are cited in the Official Journal with restrictions, and one restriction is unusually concrete. The citation in Implementing Decision (EU) 2025/138 carries a notice that EN 18031-1 does not confer a presumption of conformity if, when applying its clauses 6.2.5.1 and 6.2.5.2, "the user is allowed not to set and use any password".
That single sentence disqualifies a lot of hardware. A transmitter shipped with a fixed pairing code and no requirement to set a password cannot lean on the harmonised standard. It does not automatically make the product illegal, but it removes the easiest route to demonstrating conformity, and a buyer's compliance department will find it.
| Attack class against industrial radio remote control | What the attacker does | Question to put to the supplier |
|---|---|---|
| Capture and replay | Records a valid telegram and rebroadcasts it later to make the crane move | Is the link encrypted, and are telegrams protected against replay with a counter or timestamp? |
| Command injection | Decodes the telegram structure and substitutes a different command | Is there message authentication over the command payload, not only over the address? |
| Malicious re-programming | Rewrites the mapping between an operating element and a machine output | Can the firmware be written without a signed image and a physical service step? |
| Malicious re-pairing | Emulates the original transmitter so the receiver accepts a new one | Does pairing require physical access to the receiver and an authorised key? |
The four attack classes above are the taxonomy used by HBC-radiomatic in its published white paper on security in industrial radio remote control, which also notes that the company has provided fully encrypted radio transmission for more than a decade and submits systems for external penetration testing where feasible. That is the standard a serious supplier now works to. It is also a reasonable benchmark for a buyer comparing a European remote against a cheaper one: the question is not whether the datasheet says "encrypted", it is which of the four classes is closed and how you would prove it.
IEC 62443 is the industrial answer to "how do I show I did this properly", and it does not replace CE marking. It is a certification of your development process and your product's technical security requirements. The CE file still has to exist.
Three parts matter to a crane builder: 4-1 for the secure development lifecycle, 4-2 for the technical security requirements of the component, and 3-3 for the system. The published 2026 scheme fees and assessment ranges give a usable order of magnitude.
| What is certified | Standard | Scheme fee | Assessment, typical range |
|---|---|---|---|
| Secure development lifecycle | 62443-4-1 | USD 1,500 per year | EUR 15,000-35,000 at maturity level 2 |
| Component | 62443-4-2 | USD 1,200 per component or 1,500 per family, per year | EUR 25,000-50,000 on top of a certified 4-1 process |
| System | 62443-3-3 | USD 1,200 per year | EUR 30,000-50,000 |
| First device certification, all-in | ISASecure scheme | Included above | USD 50,000-75,000, per the scheme's own FAQ |
The standards themselves are the cheapest line and the one most often skipped. IEC sells each part separately: 62443-4-1 is CHF 335 and 62443-4-2 is CHF 405, so a product supplier's minimum set is CHF 740. The full set needed to understand what a plant will hold its service providers to is under CHF 3,000. Buying the standard is cheaper than paying a consultant to summarise it.
There is a second route that matters for the Machinery Regulation specifically. Certification under a cybersecurity scheme adopted under Regulation (EU) 2019/881 gives a presumption of conformity with Annex III sections 1.1.9 and 1.2.1 of the MR. The current scheme is the EUCC, established by Implementing Regulation (EU) 2024/482, applicable since 27 February 2025, with two assurance levels, "substantial" and "high". Self-assessment is not allowed under EUCC. For a crane builder that wants one certificate to serve both laws, that is the mechanism, and it is priced like a serious project rather than a document review.
Nobody in this industry publishes a per-unit number, so here is ours. The figures below are SIEC planning estimates for a three-model range of PLC-controlled cranes, built from our own quotations for testing and documentation work. They are not a published statistic and they will move with the scope of the control system.
| Work package | First year | Recurring |
|---|---|---|
| Threat model and cyber risk assessment added to the safety file | 5-8 engineer-days | 1-2 days per model change |
| SBOM build and refresh for controller, HMI and gateway | 4-6 days | 1-2 days per quarter |
| External penetration test of gateway and radio link | EUR 8,000-15,000 | EUR 8,000-15,000 every 2-3 years |
| Documentation, declaration of conformity, instruction manual update | 3-5 days | 1-2 days per year |
| Vulnerability handling and 24-hour reporting duty | Process setup, 3-4 days | 4-8 days per year plus on-call cover |
| Optional: EUCC or IEC 62443-4-2 certification | EUR 40,000-90,000 | Scheme fees plus surveillance audit |
| Total without third-party certification | EUR 25,000-55,000 | EUR 10,000-25,000 per year |
Amortised over output, the picture changes completely. At forty cranes a year the first-year cost is EUR 625 to 1,375 per unit. At eight cranes a year it is EUR 3,100 to 6,900 per unit, which is the same order as the freight on a single 20 tonne machine. The recurring figure is what decides whether a small builder can stay in the segment: EUR 10,000 to 25,000 a year does not scale down with volume, so the fixed cost per crane rises as the order book shrinks.
The one line people underestimate is the reporting duty. A 24-hour clock means somebody has to be reachable at 3 a.m. European time from Zhejiang. In practice that means either a European service partner with an incident process, or a rota. Both cost money, and neither is on a quotation.
Buyers who understand the two regimes write different purchase orders than buyers who do not. These are the clauses we now see in European enquiries and the ones we would put in if we were on the buying side.
| Clause | Wording that works |
|---|---|
| 1. Inventory | List every product with digital elements in the crane, with make, model and firmware version |
| 2. Declarations | Provide the CE declaration of conformity for each third-party item, or state in writing that none exists |
| 3. Support period | State the support end date in the instruction manual and name the person responsible for it |
| 4. Remote access | Outbound-only connection, no inbound port, per-site credentials, no shared service account |
| 5. Radio link | Encrypted transmission, replay counter, mandated password on first use, physical pairing step |
| 6. Updates | Signed firmware, documented offline update path, rollback procedure |
| 7. SBOM | Deliver on request within five working days, under NDA, refreshed at each firmware release |
| 8. Reporting | Notify the buyer within 24 hours of becoming aware of an actively exploited vulnerability affecting the crane |
| 9. Escalation | Named security contact with a response time, not a general sales address |
| 10. Change control | Any substitution of a controller, HMI or gateway requires written approval and an updated file |
Clause 10 is the one that protects the buyer from the most common real-world failure. A controller gets swapped in the factory because of a supply delay, nobody updates the documentation, and eighteen months later the crane on site no longer matches the file that was declared. Under the Machinery Regulation that is a conformity problem. Under the CRA it is a documentation failure that sits in the EUR 10 million bracket.
Orders placed now land in the window where the two regimes overlap, and the sequence matters more than the paperwork.
| Stage | Timing | What has to be ready |
|---|---|---|
| Order and design freeze | Q4 2026 to Q1 2027 | Component inventory and supplier declarations fixed with the order, not after |
| Machinery Regulation applies | 20 January 2027 | Annex III 1.1.9 evidence: connectivity architecture, logged interventions, protected safety software |
| CRA reporting duty on existing fleet | Already live since 11 September 2026 | A named contact and a written triage process for every connected crane already in the EU |
| CRA main obligations | 11 December 2027 | CRA conformity assessment, declaration, CE, SBOM, declared support period |
| First CRA audit cycle | 2028 | Evidence that the vulnerability process actually ran, not just that it was written |
The practical consequence is that a crane delivered in the second half of 2027 has to satisfy the Machinery Regulation at delivery and will be inside the CRA regime within months. Designing the file once, for both, is cheaper than retrofitting one into the other. The control system is where the two overlap: 1.1.9 asks whether an intervention can corrupt a safety function, and the CRA asks whether you can find out about it and fix it.
Crane cyber compliance is not a European trick to keep Chinese cranes out. It is a documentation and process law, and a factory that already builds a proper CE file is closer to compliance than the deadline suggests. What it does punish is the arrangement most exporters currently rely on: a third-party PLC and gateway, a shared password, an undocumented update path, and nobody who owns the question.
The report duty is the part to fix first, because it is already in force and it costs almost nothing to set up properly. A named contact, a short written triage process, and a rule that any customer report of unusual crane behaviour reaches that contact within the hour. That is a week of work. The alternative is discovering the obligation in the middle of an incident, with a 24-hour clock already running and an importer asking why they were not told.
Yes, if any part of it is a product with digital elements that connects directly or indirectly to another device. A crane with a PLC and an HMI on a local network, with no route to the internet, is still in scope. The regulation covers indirect connection too, and a technician's laptop plugged into the cabinet is a connection. What changes without internet access is the practical risk, not the legal scope.
No. If the crane carries your name or trademark, you are the manufacturer under the CRA, and the reporting duty is yours. Your distributor is an importer if they place the product on the market, which gives them verification duties but does not transfer your obligations. Putting your brand on the machine and your distributor's name on the paperwork does not move the liability.
The radio remote is radio equipment and also a product with digital elements. The Radio Equipment Directive cyber requirements have applied since 1 August 2025 through Delegated Regulation 2022/30, with EN 18031-1 and EN 18031-2 as the harmonised standards. The CRA adds a separate horizontal layer covering the whole product and its lifecycle. Do not assume one certificate closes the other; the Commission's guidance on combining instruments is that the manufacturer must demonstrate the synergies.
You still notify. The 72-hour deadline is for the full notification, not for the fix. The final report on an actively exploited vulnerability is due no later than 14 days after a corrective measure is available, which is a different clock and recognises that a fix takes longer than a notification. What you must not do is wait for the fix before telling anyone.
No. IEC 62443 is not referenced as a harmonised standard giving automatic presumption of conformity under the CRA. What the Machinery Regulation does provide is that certification under a scheme adopted under Regulation (EU) 2019/881 gives a presumption of conformity with Annex III sections 1.1.9 and 1.2.1. IEC 62443 is the practical way to build the process, and a buyer may ask for it, but it is not the legal gate. For a hoist sold as a separate product, the same logic applies to its own controller and declaration.
Yes. The Commission stated on 11 September 2026 that the reporting obligations apply to all products with digital elements made available in the EU, including those already on the market. The duty attaches to the manufacturer, not the sale date. In practice, most 2018 cranes have no remote connection and no way for you to learn about an exploited vulnerability, which is an argument for documenting that fact rather than assuming the question will not be asked.
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