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Connected Products Exported to the EU: Data Compliance and Cybersecurity Certification Guidelines

Edit: GCDC  Affiliation: Certification Information  Views: 105  Release time: 2025-12-12

With the rapid development of Internet of Things (IoT) technology, almost all connected products, from smart homes and wearable devices to industrial gateways, are facing unprecedented compliance challenges when entering the EU market. The EU considers cybersecurity and personal data protection as part of product security and incorporates it into the system of mandatory regulations. Among them, the core regulations include the General Data Protection Regulation (GDPR) and the new cybersecurity provisions in the Radio Equipment Directive (RED).

 

For Chinese manufacturers, completing professional EU data bill processing and ensuring that products meet network security and privacy protection requirements is the key to avoiding trade risks and maintaining market competitiveness.

 

1. Two regulatory pillars of networked product compliance

 

Connected products must meet the requirements of the following two pillar regulations in the EU:

 

1. GDPR ( Data Protection):

Impose strict requirements on how personal data is collected, used, stored and deleted throughout the product's lifecycle. All processing behaviors involving user identity information, location information, and biometric data must follow the "legality, fairness, and transparency" principles of GDPR.

 

2. RED Directive cybersecurity provisions (mandatory):

Since 2024, the delegated act on cybersecurity in the European Union's RED Directive (2014/53/EU) has come into force, requiring all radio equipment to have the ability to resist cyberattacks, protect personal data and prevent fraud. The current industry-recognized evaluation standards mainly refer to * * ETSI EN 303 645 * * (Consumer Internet of Things Security Standard).

 

2. Core technical review points handled by the EU Data Act

 

Connected products When conducting compliance assessments, the focus of technical review has shifted from traditional hardware to software and communications. The following are the core compliance requirements:

 

Default Credential Management: Disables the use of generic, default factory passwords, or provides the option to reset to weak passwords. The product must force the user to set a strong password or adopt a random unique factory password ("one machine, one password").

Data transmission encryption: The communication between the device and the cloud/App must adopt the latest and powerful encryption protocol (such as TLS 1.2/1.3) and use industry-recognized encryption algorithms.

Security update mechanism: Manufacturers must commit to providing software security updates and establish transparent vulnerability disclosure mechanisms. The update mechanism itself must be secure and prevent malicious firmware from being installed.

Port and service security: Devices must disable unnecessary network services and ports (e.g., unencrypted Telnet, HTTP) from unauthorized access.

Transparency of data processing: In the product manual and App, users must be informed of the purpose and scope of data collection in clear and concise language.

 

3. Compliance assessment and certification process

 

To handle the EU Data Act, the issuing authority does not directly issue the GDPR certificate, but conducts systematic technical evaluation and verification through a third-party organization. Usually, the process includes:

 

Step 1: Gap Analysis and Architecture Review:

According to the requirements of ETSI EN 303 645 and RED directive, the technical team of GTG Guangtest Group conducted a preliminary review of product firmware, App and cloud architecture to determine non-compliance items.

 

Step 2: Penetration Testing:

Through professional network security testing, discover and verify possible vulnerabilities in the actual use environment of the product, such as buffer overflow, session hijacking, SQL injection, etc.

 

Step 3: Improve the document system:

Assist enterprises to improve the legal documents such as the "Data Processing Agreement", "Privacy Policy" and "Security Vulnerability Management Process" required by GDPR.

 

Step 4: Compliance verification and reporting:

Issue a cybersecurity assessment report (Evaluation Report) that meets EU requirements, which is a key document to prove to market regulators that products meet the cybersecurity requirements of the RED Directive.

Professional advice:

IoT products usually require the use of * * EU Representative * * as the compliance contact, responsible for handling regulatory matters, cooperating with market spot checks and providing technical documentation within the EU, which is a mandatory requirement under GDPR and new regulations.

 

4. Professional support from GTG Guangce Group

 

The EU regulatory environment is complex and constantly updating, and the compliance challenges for connected products are long-term and ongoing. GTG Guangce Group has a professional network security assessment laboratory and a team of regulatory experts, which can provide one-stop services from "design security" consulting in the product project establishment stage to ETSI EN 303 645 standard testing, penetration testing and GDPR compliance document preparation. Ensure that the company's products are safely and stably sold in the EU market.

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