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European Network for Cyber Security

ENCS

The European Network for Cyber Security (ENCS) is a non-profit member organization that brings together critical infrastructure stakeholders and security experts to deploy secure European critical energy grids and infrastructure.

Lobbying Activity

Response to Technical description of important and critical products with digital elements

15 Apr 2025

As a member organization representing 29 distribution and transmission system operators in Europe, ENCS is concerned about the possible impact of two of the definitions of critical products on the electricity sector. For smart meter gateway, the current definition does properly reflect the implicit definitions used in the sector. Our only concern is that the definition is complex and hence may be read in different ways. In our comments, we propose a rephrasing to remove the ambiguity. For the hardware devices with security boxes, we are concerned that the current definition is too broad. Most products that include countermeasures against physical attacks seem to fall under the proposed definition. This includes many products that are not currently covered under certification schemes such as EUCC, and that do not pose a critical risk to essential entities under NIS 2 if they are compromised through a physical attack. We think the proposed definition needs to be refined to incorporate these properties that critical products should have according to point (46) in the CRA recitals.
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