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That's a nice legal theory you have there.
Let's say you're an engineer at one such company, and you want to expose a UART serial interface to allow the device you're selling to be debuggable and modifiable for the subset of end-users who know what they're doing. You say "this is part of the consumer-facing functionality". The regulator comes back and says "ok, where's the documentation for that consumer-facing functionality" and you say "we're not allowed to share that due to NDAs, but honest this completely undocumented interface is part of the intended consumer-facing functionality".
How do you expect that to go over with the regulator? Before that, how do you expect the conversation with the legal department at your company to go when you tell them that's your plan for what to tell the regulator if they ask?
I don't see any documentation requirement for user interfaces. But it would seem that they are required to put on the table that they are intending for it to be a user interface. "We have assessed that this interface provides user benefits, e.g., debugging." Simple.
Again, that interpretation is nice if correct. Can you point to anything in the document which supports the interpretation that saying "We have assessed that leaving this debug interface provides user benefit because the debug interface allows the user to debug" would actually be sufficient justification?
My mental model is "it's probably fine if you know people at the regulatory agency, and probably fine if you don't attract any regulatory scrutiny, and likely not to be fine if the regulator hates your guts and wants to make an example of you, or if the regulator's golf buddy is an executive at your competitor". If your legal team approves it, I expect it to be on the basis of "the regulator has not historically gone after anyone who put anything even vaguely plausible down in one of these, so just put down something vaguely plausible and we'll be fine unless the regulator has it out for us specifically". But if anything goes as long as it's a vaguely plausible answer at something resembling the question on the form, and as long as it's not a blatant lie about your product where you provably know that you're lying, I don't expect that to help very much with IoT security.
And yes, I get that "the regulator won't look at you unless something goes wrong, and if something does go wrong they'll look through your practices until they find something they don't like" is how most things work. But I think that's a bad thing and the relative rarity of that sort of thing in tech is why tech is one of the few remaining productive and relatively-pleasant-to-work-in industries. You obviously do sometimes need regulation, but I think in a lot of cases, probably including this one, the rules that are already on the books would be sufficient if they were consistently enforced, but they are in fact rarely enforced and the conclusion people come to is "the current regulations aren't working and so we need to add more regulations" rather than "we should try being more consistent at sticking to the rules that are already on the books", and so you end up with even more vague regulations that most companies make token attempts to cover their asses on but otherwise ignore, and so you end up in a state where full compliance with the rules is impractical but also generally not expected, until someone pisses off a regulator at which point their behavior becomes retroactively unacceptable.
Edit: As a concrete example of the broader thing I'm pointing at, HIPAA is an extremely strict standard, and yet in practice hospital systems are often laughably insecure. Adding even more requirements on top of HIPAA would not help.
That quote would not be correct. You have not "assessed that leaving a debug interface..." because it is not a debug interface, by the definition of "debug interface" given in the document. You have assessed that leaving that physical interface provides user benefit, because the physical interface allows the user to debug. You have determined that the physical interface in question is "part of the consumer-facing functionality". That is right there in the definition, in the document. You have made that assessment directly following the instruction given in 5.6-3, in the document.
So in your interpretation, 5.6-4 could be replaced by "list the communication interfaces your product has. For each of them, either ensure the interface is disabled or state that the interface is intentionally enabled because a nonzero number of your customers want it to be enabled in a nonzero number of situations".
I think that would be fine, if so, but I don't understand why provisions 5.6-3 and 5.6-4 would be phrased the way they are if that were the case.
I don't see what's awkward at all about the phrasing. They want people to reduce attack surface, so they say that they should not expose interfaces thoughtlessly (3). Obviously, they can thoughtfully choose to expose an interface, for precisely the reasons you present, which is why they give plenty of latitude for manufacturers to assess that they would like to expose it. It seems like manufacturers have wide latitude, too. There doesn't seem to be any real boundary on their assessment; they just have to be like, "Yeah, we thought about it."
Then, moreover, they know that there have been many high-profile instances of products shipping, having an interface exposed that is trivially-attackable, and when it's attacked, the manufacturers ignore it and just say some bullshit about how it was supposed to just be for the manufacturer for debugging purposes, so they're not responsible and not going to do anything about it. It's a bullshit thing by bad entity manufacturers who don't care. So, while they're well-aware that manufacturers sometimes want a manufacturer-only interface for perfectly fine reasons, all (4) is doing is saying, "Yeah, if that's what you're going for here, don't be an idiot; disable it before you ship it."
This is a very natural way of doing things. Honestly, I probably would have not done as good of a job if I had tried to put this set of ideas together from scratch myself.
Was "lol we didn't mean to leave that exposed" a get-out-of-liability-free card by UK laws before this guidance came out? If so, I can see why you'd want this. If not, I'd say the issue probably wasn't "not enough rules" but rather "not enough enforcement of existing rules" and I don't expect "add more rules" to be very useful in such a case, and I especially don't expect that to be true of rules that look like "you are legally required to use your best judgement".
I agree, but I don't think it's possible to legally compel companies to thoughtfully consider the best interests of their users.
Neither would I. My point wasn't "the legislators are bad at their job", it was "it's actually really really hard to write good rules, and frequently having bad explicit rules is worse than having no explicit rules beyond 'you are liable for harm you cause through your negligence'".
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