Cybersecurity in RED: Adapting to Article 3.3(d), (e), and (f) Requirements

Understanding Articles 3.3(d), (e), and (f)

With growing cybersecurity threats in the EU, the obligations of cybersecurity in RED focus on three key areas: network protection, data privacy, and fraud prevention. Each article introduces specific technical and design expectations that must be addressed throughout the product development lifecycle.

Article 3.3(d) – Protection of Networks

Article 3.3(d) requires that radio and wireless equipment be designed to prevent harm to electronic communications networks. Devices must be safeguarded against unauthorized access, malware deployment, and misuse of network resources, such as their inclusion in botnets or initiation of Distributed Denial of Service (DDoS) attacks.

This means that manufacturers must implement traffic filtering, secure default configurations, access controls, and secure software update mechanisms. These measures are essential to preventing the exploitation of devices as entry points into larger network infrastructures.

Article 3.3(e) – Protection of Personal Data and Privacy

This provision introduces cybersecurity in RED that aligns closely with the General Data Protection Regulation (GDPR). Devices must adhere to privacy-by-design and privacy-by-default principles, ensuring that personal data is collected only when necessary, with user consent, and processed securely.

Manufacturers must consider data encryption, secure communications protocols, access limitation, and user transparency features. This ensures the device is functioning correctly, and protects the rights and personal information of its users.

Article 3.3(f) – Protection from Fraud

Connected devices that can initiate financial transactions or manage personal identity are increasingly being targeted for fraudulent activities. Article 3.3(f) requires embedded technical safeguards to detect, prevent, and respond to fraud, including unauthorized transactions and identity theft.

Examples include strong authentication mechanisms, digital signatures, secure elements, and anti-tampering features. These elements protect both the end user and the digital service ecosystem.

Types of Equipment Affected by Articles 3.3(d), (e), and (f)

Any radio equipment that connects to a network, processes personal data, or can be used in a fraudulent context falls under their jurisdiction. Devices commonly impacted include:

• Smartphones, tablets, and laptops: These devices are considered high-risk due to their extensive access to personal data and network resources.
  
  
• Smart home appliances (e.g., connected thermostats, security cameras): These devices often lack proper security configurations, making them targets for network disruption or privacy violations.
  
  
• Wearables and fitness trackers: These may collect health data, location information, and personal identifiers, placing them under Article 3.3(e).
  
  
• Children’s toys with microphones or cameras: These present heightened privacy and safety concerns, especially under Articles 3.3(e) and (f).
  
  
• Routers, access points, and modems: As direct conduits to electronic communications networks, these must include protections under Article 3.3(d).
  
  
• Mobile payment-enabled devices and e-banking tools: These are particularly subject to fraud prevention measures under Article 3.3(f).
  
  

Manufacturers must assess each product’s use case, data processing profile, and communication capabilities to determine which measures of cybersecurity in RED compliance are required. 

Key Requirements and Implications of Cybersecurity in RED

Successfully complying with Articles 3.3(d), (e), and (f) of RED requires manufacturers to embed robust cybersecurity principles into every stage of their product’s lifecycle.

This begins at the concept and design phase, where threat modeling and security architecture must be defined, and extends all the way through development, production, deployment, and long-term support. 

Compliance is not simply a matter of ticking boxes. It demands a comprehensive, proactive approach to cybersecurity in RED that aligns with modern threat landscapes and user expectations.

Protecting Networks - Article 3.3(d)

To meet the requirements of Article 3.3(d), manufacturers must prioritize protecting electronic communication networks from potential harm caused by their devices. One of the most fundamental principles is the implementation of secure default configurations. Devices should never be shipped with default usernames, passwords, or open communication ports that can be easily exploited. Instead, they must be configured to minimize exposure and enforce authentication from the outset.

Another critical aspect is the integrity of software and firmware updates. These must be authenticated through cryptographic checks, ensuring that only verified code can be installed on the device. This prevents attackers from injecting malicious firmware, which could be used to hijack the device or infiltrate broader network infrastructure.

Network protection also involves limiting the device’s potential to be used as a tool in larger cyberattacks, such as DDoS campaigns. Devices must be resistant to such misuse, which requires incorporating behavioral monitoring and rate-limiting mechanisms to detect and mitigate abnormal traffic patterns. Additionally, they must support secure communication protocols, such as TLS, to protect data transmitted over networks and prevent eavesdropping or session hijacking.

Efficient resource management plays a complementary role in network security. Devices must be engineered to avoid excessive or malformed traffic that could overwhelm communication systems, degrade performance, or be exploited by malicious actors. This is especially important for IoT devices deployed at scale.

Manufacturers often find the technical complexity of these requirements challenging, especially when combined with commercial time-to-market pressures. This is where CCLab adds value by supporting manufacturers through Common Criteria methodologies. These internationally recognized standards offer a systematic approach to evaluating and verifying the security of devices, providing the evidence and guidance needed to demonstrate RED compliance and effectively mitigate network-related risks.

Protecting Privacy and Personal Data – Article 3.3(e)

Article 3.3(e) introduces cybersecurity in RED that directly intersects with privacy regulations, particularly the General Data Protection Regulation (GDPR). Manufacturers must design products that respect personal data privacy from the outset—this means embracing privacy-by-design and privacy-by-default principles in every functional and architectural decision.

A cornerstone of this obligation is data minimization. Devices must be designed to collect only the personal data necessary for their intended functionality. Unnecessary or excessive data collection increases the attack surface and introduces additional compliance risks. This selective data approach must be combined with robust protection measures, such as end-to-end encryption. 

Personal data must be encrypted both when it is in transit over networks and when it is stored on the device or in associated backend systems, ensuring that even if data is intercepted or accessed without authorization, it remains unreadable and unusable.

User autonomy and informed consent are equally critical. Devices must be equipped with interfaces that communicate data practices and provide users with real choices about what data is collected and how it is used. Collecting consent must go beyond checking a box, it should reflect meaningful user engagement. Behind the scenes, access to personal data must be governed by role-based controls, ensuring that only authorized users or services can retrieve or process sensitive information.

Transparency remains an overarching requirement. Users must be made aware of data flows, sharing practices, and retention periods through clear, accessible privacy notices. These obligations not only help protect users but also foster trust and improve adoption rates for connected products.

Given the overlap with GDPR, manufacturers are advised to align their RED compliance strategies with broader cybersecurity compliance frameworks. Organizations like CCLab offer critical insights and practical support to ensure that privacy protections are seamlessly integrated into the product lifecycle, reducing regulatory risks and enhancing product credibility.

Fraud Prevention – Article 3.3(f)

The final cybersecurity in RED, Article 3.3(f), focuses on safeguarding users and service providers from fraud. With the increasing use of connected devices in financial transactions, identity verification, and secure communications, these protections are essential for maintaining trust in digital services.

At the core of fraud prevention is user authentication. Devices must support strong authentication mechanisms such as multi-factor authentication (MFA), which may involve passwords, biometrics, or cryptographic tokens. These mechanisms help ensure that only legitimate users can access sensitive functions or initiate transactions. Alongside authentication, digital signatures play a vital role in confirming the authenticity and integrity of communications and transactions, preventing spoofing or unauthorized manipulation.

Fraud prevention must also be embedded into the device hardware. This includes secure boot processes and anti-tampering mechanisms that prevent attackers from modifying the device’s firmware or substituting components with malicious equivalents. These hardware-level protections create a trusted foundation for all higher-layer security functions.

Detection and response capabilities are just as important as preventative controls. Devices must be capable of monitoring activity and identifying suspicious or anomalous behavior. This might involve flagging repeated failed authentication attempts, unusual transaction patterns, or unexpected communications with third-party servers. Such monitoring enables real-time mitigation of threats and contributes to broader fraud intelligence frameworks.

In addition to these technical measures, devices involved in digital transactions or identity services must comply with relevant EU regulations, including PSD2 and eIDAS 2.0. These frameworks impose additional requirements around secure communications, electronic identification, and trust services. Ensuring conformity with these regulations reinforces the device’s legitimacy and enhances its interoperability with European financial and identity infrastructures.

By helping manufacturers integrate these fraud prevention capabilities, CCLab supports not only cybersecurity in RED but also broader digital trust goals. Their expertise ensures that the technical foundations for secure transactions are properly implemented, evaluated, and documented.

Cybersecurity in RED: How can CCLab help?

Adhering to the cybersecurity in RED involves more than simply adding security features to products. Manufacturers must design and build devices within a secure development lifecycle, conduct in-depth risk assessments, and produce comprehensive documentation that demonstrates compliance with Articles 3.3(d), (e), and (f). These tasks require a combination of technical precision and well-documented processes, from secure coding practices to the preparation of detailed technical files.

Collaborating with an accredited laboratory like CCLab, offers manufacturers a critical advantage in navigating this demanding landscape and mitigating the challenges of RED. As a Common Criteria evaluation facility and RED compliance partner, CCLab carries out rigorous product security evaluations and tailored penetration testing to identify and mitigate vulnerabilities. Their consulting team guides aligning product development with cybersecurity in RED, ensuring manufacturers understand and address each requirement.

Secure Design and Technical Documentation Support

In addition to regulatory consulting, CCLab assists in building secure software and hardware architectures that support privacy, resilience, and fraud protection from the design phase. They also help create the technical documentation needed to demonstrate conformity, such as risk analyses, threat models, and compliance reports, which are essential for successful RED declarations and audits.

Preparation for Broader Certification Schemes

For manufacturers looking to certify under broader European frameworks, such as the EU Cybersecurity Certification (EUCC) scheme or Common Criteria, CCLab offers structured preparation and support. Their deep understanding of overlapping standards ensures a streamlined path toward certification that satisfies both RED and future regulatory requirements.

Summary

The introduction of Articles 3.3(d), (e), and (f) into the RED marks a pivotal shift in the EU’s approach to digital product safety. No longer is compliance only about electrical safety or spectrum efficiency; cybersecurity in RED now takes center stage.

Understanding the implications of RED in the EU is essential for manufacturers aiming to place secure and compliant radio equipment on the European market. This includes implementing technical safeguards, secure communication, access controls, and robust identity verification systems.

Failure to comply is more than a regulatory risk. It’s a reputational and business threat. By working with experienced cybersecurity labs like CCLab, manufacturers can navigate these changes confidently, ensuring their products are not only compliant but also secure, trusted, and future-ready.