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INDUSTRY 4.0/SMART FACTORIES
internet or via an internet-connected device. The updates to the RED are also intended to
enhance data privacy by incorporating safeguards to protect personal data and the privacy of users and subscribers. This covers equipment that can communicate itself over the internet, processing personal, traffic and location data. The updates also contain features that are intended to enhance fraud protection, covering equipment that can communicate itself over the internet and via an
internet-connected device, thereby enabling the holder or user to transfer money, momentary value or virtual currency. These provisions will become mandatory on
1st August 2025 and manufacturers of radio connected devices must be compliant by that date or face potential action. The reason behind this is that an increasing number of products 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. It is important to note that these new requirements have not been replicated in the UK’s Radio Equipment
Regulations. It should also be noted that some products are out of scope (for some articles) such as medical devices, aviation, motor vehicles and electronic road toll systems.
WHAT DO THE ESSENTIAL REQUIREMENTS ACTUALLY MEAN? Article 3.3(d) – Cybersecurity 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 therefore 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) It will protect users who wish to use radio products to process financial transaction and protect them from compromise and fraud.
COMPLIANCE TIMESCALES 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 it is yet to be officially published, 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. The Delegated Acts were cited in the EU’s Official Journal on 12 January 2022. The legislation is presently in force, and compliance with the essential requirements becomes mandatory from 1st August 2025. This means that the entire machinery supply chain (manufacturers, importers and integrators of radio equipment) now only have little more than a year to ensure their internet-connected radio devices adhere to the new provisions. This may require some significant adaptations to how radio-enabled machinery is manufactured and supplied, and time will go very quickly. So, the manufacturers should start including the new requirements into product technical specifications as early as possible. I cannot stress enough how important it is that manufacturers start preparing now by looking at what effort they need to put in. It can be quite considerable and leaving it to the last minute will cause delays in compliance.
TÜV SÜD
www.tuvsud.com/uk
FACTORY&HANDLINGSOLUTIONS | MAY 2024 11
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