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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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