Olle, Thanks, I wasn’t aware of that open issue. This is exactly what I’m asking for more info. Will someone be assembling comments covering our concerns/issues to submit before the comment period expires, 15 April 2025? From: Olle E. Johansson <oej@xxxxxxxxxx>
Sent: Monday, March 17, 2025 3:57 AM
To: dick@xxxxxxxxxxxxxxxxxxxxxxxxx; Open Regulatory Compliance Working Group <open-regulatory-compliance@xxxxxxxxxxx>
Subject: Re: [open-regulatory-compliance] Draft Technical Descriptions There is an open issue on this: 
/O
Maybe a comment is in order for the web service api scenario. How does this look: “Under what scenarios should a Web Service API be considered in scope for the EU CRA?” Any others with a better way to phrase this question… Active Member of the CISA Critical Manufacturing Sector, Sector Coordinating Council – A Public-Private Partnership Risk always exists, but trust must be earned and awarded.™ Within such a product, which is not usable without the WebAPIs and part of the „data processing solution“ as Tobie said would be in scope. However WebAPIs by themselves, offered as a service, might not be in scope. (for example, depends on the context I guess) --
Dr. Florian Idelberger
Karlsruher Institut für Technologie (KIT)
Zentrum für Angewandte Rechtswissenschaft (ZAR)
Institut für Informations- und Wirtschaftsrecht
Vincenz-Prießnitz-Str. 3, D-76131 Karlsruhe
E-Mail: florian.idelberger@xxxxxxx
KIT - Universität des Landes Baden-Württemberg und
nationales Forschungszentrum in der Helmholtz-Gemeinschaft Thanks for sharing your insights Tobie. Much appreciated. Many of the product listed in Annex I and Annex II depend on “Web Service API’s” to function, for example: 17. Smart home products with security functionalities, including smart door locks, security cameras, baby monitoring systems and alarm systems Does this example imply that the Web Service API’s used by these devices are also in scope for the EU CRA requirements? Thanks for your help in understanding these details. <image012.png> <image013.png> <image014.png> Active Member of the CISA Critical Manufacturing Sector, Sector Coordinating Council – A Public-Private Partnership Risk always exists, but trust must be earned and awarded.™ Thanks for your question, Dick. The product categories listed in this draft regulation are only for important and critical categories. Most products that are in scope of the CRA are actually not part of those two categories. I opened an FAQ on the topic here: https://github.com/orcwg/cra-hub/issues/166. Additionally, wrt your question about Web APIs, it depends whether they're part of the remote data processing solutions of products who are in scope of the CRA (in which case they're also in scope, see FAQ tmp-2) or not (in which case they're not in scope, see FAQ tmp-156). Before I open my big mouth and submit comments, I want to get some help from this group. Looking at the product categories listed in Annex I of the standards request, I can’t determine if a “Web Service API” will be “in scope”. Does anyone have thoughts on this? Are “Web Service API” products considered in scope based on the Annex I and Annex II descriptions? <image012.png> <image015.png> <image016.png> Active Member of the CISA Critical Manufacturing Sector, Sector Coordinating Council – A Public-Private Partnership Risk always exists, but trust must be earned and awarded.™ Hi all,
as you might have seen already, the Draft Technical Descriptions have been published on the EC website.
Time until April 10th for comments.
The Expert Group CRA of the will then be in charge, together with the Commission, to improve the definitions based on the comments received. Best Regards,
Steffen Zimmermann
Industrial Security @ VDMA
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