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RED-cybersecurity smart lock 2026/2027 – importer control, EN 18031 & batch block | Word/PDF/Excel
RED-cybersecurity smart lock 2026/2027 – importer control, EN 18031 & batch block | Word/PDF/Excel
- File format
- DOCX, PDF, XLSX
- Document language
- Five Swedish working documents Swedish user guide and English User Guide. Excel in Swedish.
- Number of files
- 7
Digital download. No physical product is shipped.
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About this template
Do you import Wi-Fi or Bluetooth-controlled smart locks into Sweden or the EU? With this niche Word/PDF/Excel package, you can document which RED cybersecurity requirements actually apply, request relevant evidence from the manufacturer, and track every model, firmware version, and batch to make a well-founded decision. Designed for Swedish importers and product liability holders – not a general IT security policy.
From 1 August 2025, certain radio equipment will be subject to additional cybersecurity requirements under the RED and delegated regulation (EU) 2022/30. The requirements may apply to equipment with a direct or indirect internet connection via an app or gateway. An important change is that this regulation will be repealed on 11 December 2027 by (EU) 2026/339, when relevant CRA requirements take over. Historical checks of earlier products may continue.
Package Contents
7 editable Word documents (five Swedish working templates, Swedish user guide, English User Guide), 7 corresponding searchable PDF files, and 1 Excel workbook with nine tabs. A total of 15 files in a compressed ZIP for future digital download. The PDF versions are not interactively fillable.
What the Files Contain
Practical checklists and fields for product model, firmware, connection chain, actor role, requirement assessment under RED 3.3(d/e/f), harmonised standards, supplier declaration, test evidence, non-conformities, batch decisions, and the transition to CRA. The Excel workbook includes status options and tested summary formulas, but does not make any legal or technical decisions for you.
All Documents in the Package
| File | What It Helps You Do |
|---|---|
| 01 – Role and Applicability Assessment | Classify Bluetooth/Wi-Fi, gateway, manufacturer/importer, date, and RED 3.3(d/e/f). |
| 02 – Supplier Letter and Documentation Requirements | Request the relevant EU declaration, CE traceability, standard versions, and test evidence. |
| 03 – Security Testing and Chain of Evidence | Document actual tests, firmware, EN 18031 assessment pathway, and limited presumption. |
| 04 – Batch Hold and Non-Conformity | Document deficiencies, supplier response, corrections, risk, and release decisions. |
| 05 – RED to CRA 2027 | Plan the transition on 11 December 2027 without losing historical RED evidence. |
| 06 – Swedish User Guide | Step-by-step workflow with concrete scenarios and legal boundaries. |
| 07 – English User Guide | English instructions for the Swedish working templates and Excel workbook. |
| 08 – Excel Register, Nine Tabs | Overview, model register, role/scope, evidence, tests, non-conformities, batch decisions, transition, and Read Me. |
Who Is the Template For?
Importers, small and medium-sized technology companies, brand owners, and quality assurance holders who review imported internet-connected smart locks, including locks where a Bluetooth-connected mobile app or gateway provides an indirect internet connection. Determine separately whether the company is an importer, distributor, or takes on manufacturer responsibility under RED through branding or product modification.
RED Article 3.3(d), (e), and (f) – Correct Applicability
3.3(d) concerns network protection and applies to internet-connected radio equipment within the relevant scope. 3.3(e) concerns the protection of personal data and privacy when the equipment in question can process such data or traffic/location data. 3.3(f) concerns fraud protection for equipment that enables the transfer of money, monetary value, or virtual currency – it does not automatically follow from the product being a smart lock.
EN 18031 and CE Documentation
The harmonised standards EN 18031-1:2024 (network), EN 18031-2:2024 (personal data/privacy), and EN 18031-3:2024 (fraud protection) may be relevant depending on the actual assessment. According to the Commission Implementing Decision (EU) 2025/138, the standards have explicit restrictions. They therefore do not automatically provide full presumption of conformity; check the need for another assessment pathway, including a notified body where required.
RED to CRA – Check the Cut-off Date
1 August 2025–10 December 2027: The RED cybersecurity requirements made applicable by (EU) 2022/30 must be assessed for the products concerned. From 11 December 2027: the complementary regulation will be repealed by (EU) 2026/339, and the applicable requirements in the Cyber Resilience Act (EU) 2024/2847 must be assessed. Other RED requirements may still apply. Earlier batches may be subject to historical market surveillance.
How the Documents Are Used
- Record the model, SKU, manufacturer, firmware, and market access date.
- Assess the internet connection chain, personal data, and payment functions separately in document 01.
- Request the EU declaration, CE details, and relevant EN 18031/test documentation in document 02.
- Link actual checks to the test ID, document version, and non-conformity ID in document 03 and the Excel workbook.
- Hold affected batches if deficiencies are found and document the correction, retesting, and signed decision.
- Review future purchases and compliance plans according to the 2027 transition.
Important Limitations
- This is documentation support, not actual laboratory testing, a completed EU declaration, a notified body, or CE certification.
- Confidential technical documentation, standard text, and licences are not included.
- No test results, regulatory decisions, supplier declarations, or signatures have been fabricated.
- GDPR, other RED requirements, and product safety may need to be checked separately.
- A completed checklist does not automatically mean a particular product may be sold.
Frequently Asked Questions
Do RED cybersecurity requirements apply to a Bluetooth smart lock?
Bluetooth alone does not determine this. Assess whether the lock can connect to the internet directly or indirectly via a phone or gateway and whether specific requirements apply.
Must the importer have the manufacturer's complete technical documentation?
The importer's obligations differ from the manufacturer's. The package supports the checking and tracking of necessary information without incorrectly claiming that every importer must always hold the manufacturer's entire technical file.
Is a CE mark or EN 18031 statement sufficient?
No. Actually assess the relevant EU declaration, model documentation, scope of the standard, and published restrictions. EN 18031 does not always provide full presumption of conformity.
Does Article 3.3(f) automatically apply to all digital door locks?
No. The fraud protection provision must be assessed based on whether the equipment actually enables the transfer of money, monetary value, or virtual currency.
What happens on 11 December 2027?
Delegated Regulation (EU) 2022/30 will be repealed on that day according to (EU) 2026/339 when the CRA's main requirements come into effect. This does not retroactively change the checking of radio equipment from the earlier period.
Can the documents be used as CE certificates?
No. They do not create CE marking, EU declarations, technical laboratory tests, or notified body assessments.
Is the product legally reviewed and in English?
AI-assisted legal source check as of 10 November 2026; no external legal review. Five operational templates and the Swedish guide are in Swedish; an English guide is included, but the working templates are not translated.
Official Legal Sources
PTS – cybersecurity requirements for radio equipment · RED 2014/53/EU · (EU) 2022/30 · (EU) 2025/138, EN 18031 restrictions · (EU) 2026/339 · CRA 2024/2847.
Related Templates
For broader Cyber Resilience Act preparation, CRA Compliance 2026/2027 is available. For tracking technical vulnerabilities, Patch Management and Vulnerability Register is available. This product is instead tailored for the RED importer's checking of smart locks and the 2027 legal transition.
Version 1.0 | AI-assisted legal source check 2026-11-10 | No external legal review | Jurisdiction Sweden/EU | Word/PDF/Excel | Digital download (ZIP) only after future activation.
