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INDUSTRY 4.0/IIOT LEARNING ABOUT ‘ESSENTIAL REQUIREMENTS’
Joe Lomako, Business Development
Manager (IoT) at TÜV SÜD, takes a look at EU Security Legislation for Wireless Products, and explains the elements of the Radio Equipment Directive (RED)
s we continue to develop Industry 4.0- based production methods, more complex and convergent technologies are being continuously introduced. This means that machines are increasingly incorporating radio-based components which rely on the radio spectrum to operate.
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In Europe, the Radio Equipment Directive (RED) is applicable to all electrical and electronic devices that employ radio technology in their operation, that intentionally emit and receive radio waves at frequencies below 3000 GHz, and it establishes a regulatory framework for placing radio equipment on the market.
When the UK was still part of the EU, the RED was transposed into UK Nation Law in the form of the Radio Equipment Regulations 2017. This means that for the foreseeable future, the requirements of the UK Regulation will remain the same as those of the present mandatory requirements of the RED, although some terms are different, but throughout this article we will refer to the RED.
The RED is one of many directives and regulations which are part of the New Legislative Framework (NLF), for placing radio products on the European market. It ensures a single market for radio equipment by setting essential requirements for safety and health, electromagnetic compatibility, and the efficient use of the radio spectrum. It also provides the basis for further regulations by delegated acts adding additional legislation such as, in this case, for cybersecurity. Compliance with the RED is achieved by satisfying a number of “essential
requirements”. The existing ones for Safety and Health, EMC and Radio are well known as the “original” essential requirements. However, recently a delegated act was published activating new essential requirements with
6 MARCH 2024 | PROCESS & CONTROL
the details given in the following Articles in the RED, which the industry has collectively termed “cybersecurity”:
• 3.3d: communicate over the internet, either directly or via any other equipment • 3.3e: process personal data, traffic data or location data
• 3.3f: enable users to transfer money, monetary value or virtual currency
It is important to note that these new requirements have not been replicated in the UK’s Radio Equipment Regulations. These new RED provisions will become mandatory on 1st August 2025, which is an
extension from the original date of 1st August 2024. Manufacturers of radio equipment, that is not compliant by that date, face potential action. The reason behind this is that an increasing number of products, such as machinery, are employing radio technology in their applications. Many of these devices connect to the Internet, which could expose such products to increasing security threats and the potential to be attacked and exploited. To help manufacturers comply with these essential requirements, the European Commission issued a “standards request” to the European Standards Organizations (ESO), asking them to produce standards to assist in compliance. Further guidance is also expected from the Commission. The standards request sets out the minimum requirements, but the final standards may include further assessment criteria, and further guidance could come from the Commission. What do the Essential Requirements actually mean?
Article 3.3(d) – Protection of the network It covers radio equipment that can communicate directly through the Internet and radio equipment which can communicate over the Internet by way of another connected
device. In simplistic terms, the radio product must not, nor be able to be compromised, thereby causing harm to the network. Article 3.3(e) – Privacy
This requires radio equipment to incorporate safeguards to ensure that the personal data and privacy is secured. This includes, but is not limited to, radio equipment that can process personal, traffic and location data. Article 3.3(f) – Financial transactions It will protect users who wish to use radio products to process financial transactions and protect them from compromise and fraud. As compliance with the essential requirements becomes mandatory from 1st August 2025, the entire machinery supply chain (manufacturers, importers and integrators of radio equipment) only has approximately 16 months to ensure that internet connected radio devices incorporated into machinery adhere to the new provisions. This may require some significant adaptations to how radio-enabled machinery is manufactured and supplied. Manufacturers should start including the new requirements into product technical specifications as early as possible. Although the RED is pioneering the way forward in Europe in mandating cybersecurity of connected devices, there is presently a proposal out for a new horizontal legislation - The Cyber Resilience Act (CRA). This proposal is for a regulation on cybersecurity requirements for products with digital elements. Although only a proposal, it is a significant step forward in improving the cybersecurity of products put on the market in Europe. The work being done on the RED though will not be lost as the requirements in the CRA include all the elements expected in the RED. The date of the final publication of the CRA is yet to be announced, but is believed to be imminent.
TÜV SÜD
www.tuvsud.com/uk
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