Re: EU-CRA and the ongoing standardization work

Hi Julius,

Am 11.12.25 um 22:46 schrieb Julius Werner:
>> The version 0.0.11 will go through editHelp for editorial review (but no changes of the content itself) and afterwards it will be submitted for the first HAS assessment (means it gets the first legal scrutiny by the European Commission).
>>
>> The first commenting phase is over now, but after the HAS there will be the public enquiry, likely from January."
> Thanks, but that's still not super clear. ;) Can you try to find out
> more details? For example:
>
> * Does this mean that no new comments can't be submitted from now
> until this date in January?

You can submit comments at any time, but comments submitted now will 
probably only be considered after editorial review and/or HAS assessment 
of the current document version is done.

> * Where/how do we find out that this public enquiry has started?

There will be announcements. Werner will probably (at least that's my 
assumption) write something here on the mailing list. If not, I will 
probably do it.

> * How exactly does the process work for this public enquiry and what's
> the timeline from there to the final document?

Public enquiry is the part where everybody and their dog will comment 
regardless of knowledge and correctness. I expect a huge flood (probably 
thousands) of comments and depending on how/where you submit, various 
national standards organizations may pre-filter the comments.
The effort to get something changed will be roughly one order of 
magnitude more than during the golden time which is over now.

> * What's the last point at which we can bring up discussions about
> significant changes (e.g. adding/dropping requirements)?

That point (for firmware, i.e. "boot managers" in CRA-speak) was last 
week if you wanted the easy route. Sorry.

You can still bring up discussions within the next few months (exact 
date unknown, probably around mid Q1/2026), but any such discussion MUST 
come with a concrete suggestion for new wording and solid reasoning for 
the suggested change and in exactly the required format. It's a pretty 
formal bureaucratic process now.
The later you submit, the more difficult it will be because someone may 
already have made a similar suggestion as yours, but with unconvincing 
reasoning. Then you need extremely good reasoning to convince people to 
look at that point again after that point had been rejected previously.

At one future point in time (exact date TBD, but probably sometime in 
2026), changing anything will become practically impossible (only total 
accept or total reject of the whole document) and you have to hope for a 
next round a few years from now.


I do think it is still very much worthwhile to submit comments and 
suggestions in the public enquiry phase, but it will require additional 
effort.

My recommendation is to submit the comments in batches as soon as they 
are ready instead of waiting until all of them are ready.

Good luck!

Regards,
Carl-Daniel
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