Is a smart meter (no gateway role declared) an important product under the Cyber Resilience Act, and what does it still have to do?

No. Smart meter (no gateway role declared) is not listed in Annex III or Annex IV, so the class its function points to is default. It may use any Art. 32(1) procedure, including internal control, and every other duty of the Act applies: the essential requirements in Annex I, vulnerability handling through the support period (at least five years unless expected use is shorter), and reporting actively exploited vulnerabilities from 11 September 2026.

What does a smart meter (no gateway role declared) sold to UK consumers or in California have to show?

Under the UK PSTI rules: no universal default password, a published point of contact for security issues, a published defined support period, and a statement of compliance with the product. Under California Civil Code 1798.91.04: a reasonable security feature, and for authentication outside a local area network a password unique to each device or one the user sets before first access.

default · product function

Smart meter (no gateway role declared)

By the Annex wording, a smart meter (no gateway role declared) points to the default class, not listed in Annex III or IV. The route that class asks for: any Art. 32(1) procedure: internal control (module A), EU-type examination (module B then C), full quality assurance (module H), or a European cybersecurity certification scheme where available.

Where the match turns

A meter is not listed; a meter that also acts as the gateway of a smart metering system reads as Annex IV, point 2, so declare the gateway role where it has one.

A line that places here

example

SM-400 | smart electricity meter | EU, UK | businesses | self-assessment

Check this line

What the finder reads on these lines

10 of the 14 notes

4. No process to report an actively exploited vulnerability or a severe incident: Who notifies the CSIRT and ENISA within 24 hours when this product carries an actively exploited vulnerability, and where is the process written down?
5. No support period stated, or under five years with no reason recorded: What is the support period, how was it set, and where is its end date shown to buyers?
6. A universal default password: When will each unit ship with a unique password, or require the user to set one at first use?
7. No published vulnerability contact: Where does a researcher report a vulnerability in this product, and is that address published?
8. No security update mechanism, or unsigned updates: How does a security fix reach units already sold, and how does the device check the update is genuine?
9. No software bill of materials kept, or partial: Where is the machine-readable SBOM for this product, and does it cover at least the top-level dependencies?
10. Sold to UK consumers with no statement of compliance: Where is the statement of compliance for this product, and does it travel with every unit sold to UK consumers?
11. Manufacturer outside the EU with no authorised representative: Will the company appoint an EU authorised representative, and if not, which importer holds the documentation for the market surveillance authorities?
12. Still on sale for 11 December 2027 with no conformity route planned: Which route will this product take, and by when, so units made available from 11 December 2027 carry the declaration?
13. Sold in California with no reasonable security feature recorded: Which reasonable security feature does this device carry for California, and is it unique per device or set by the user at first use?

Clauses

12 cited

Regime	Clause	Applies when
CRA	CRA Art. 32(1) Choosing a conformity assessment procedure (default products)	sold in the EU
CRA	CRA Annex VIII Part I Module A: internal control	sold in the EU
CRA	CRA Art. 13(1) Design, development and production to Annex I Part I	sold in the EU
CRA	CRA Annex I Part I(1) Appropriate level of cybersecurity based on the risks	sold in the EU
UK PSTI	UK PSTI R.1 No universal default passwords	sold to UK consumers
UK PSTI	UK PSTI R.2 Published point of contact for security issues	sold to UK consumers
UK PSTI	UK PSTI R.3 Published defined support period	sold to UK consumers
ETSI EN 303 645	ETSI EN 303 645 5.1 (provision group) No universal default passwords	sold to UK consumers
ETSI EN 303 645	ETSI EN 303 645 5.2 (provision group) Implement a means to manage reports of vulnerabilities	sold to UK consumers
ETSI EN 303 645	ETSI EN 303 645 5.3 (provision group) Keep software updated	sold to UK consumers
California	California 1798.91.04(a) Reasonable security feature or features	sold in California, as the manufacturer
California	California 1798.91.04(b) Authentication outside a local area network: unique password or forced new credential	sold in California, as the manufacturer

The route clause, set out

CRA Annex VIII Part IModule A: internal control

Under internal control the manufacturer draws up the Annex VII technical documentation, takes all measures so that design, development, production and vulnerability handling and their monitoring ensure compliance with Annex I Parts I and II, affixes the CE marking to each conforming product, and draws up the declaration, keeping it with the technical documentation for ten years or the support period if longer. The authorised representative may handle marking and declaration under mandate.

What a notified body or authority asks to see: Internal control file: technical documentation, production and vulnerability handling monitoring records, declaration

Where lists usually fall short: Internal control treated as paperwork with no monitoring of processes

Source: EU Cyber Resilience Act (Regulation (EU) 2024/2847)