CRA product classification
Is a Automotive ECU / telematics unit covered by the EU Cyber Resilience Act?
A Automotive ECU / telematics unit may be covered by the CRA when it is a product with digital elements placed on the EU market and no exclusion applies. The preliminary category is Default (non-important). Applicable obligations and assessment routes depend on the full product context; reporting begins 11 September 2026 and general application begins 11 December 2027.
Why this category?
OEM-fit products may fall under the vehicle exclusion; aftermarket products require separate analysis. TODO(owner): review interaction with UN R155/R156.
This classification is marked borderline. TODO(owner): verify the current Commission technical description and borderline treatment before launch.
OEM-fit products may fall under the vehicle exclusion; aftermarket products require separate analysis. TODO(owner): review interaction with UN R155/R156.
Borderline cases
- Is it installed in a type-approved motor vehicle as an OEM system or component?
What you may need to do
The default route is internal control. Other routes may be available under Article 32. (Art. 32(1))
- Module A (internal control)
Top Annex I items to assess
- Vulnerability handling and no known exploitable vulnerabilities at placing on the market (Annex I)
- Secure-by-default configuration and updates (Annex I)
- Access control, confidentiality and integrity (Annex I)
- Attack-surface management and security logging (Annex I)
- SBOM, coordinated disclosure and secure update distribution (Annex I, Part II)
What applies today?
CRA Article 14 reporting obligations apply from 11 September 2026 to in-scope products already on the market as well as new products. See the Article 14 reporting tool.
Frequently asked questions
Is a Automotive ECU / telematics unit covered by the EU Cyber Resilience Act?
The CRA may apply to a Automotive ECU / telematics unit placed on the EU market as a product with digital elements, subject to the scope and exclusions. This preliminary page associates it with the default category; confirm its intended purpose and technical characteristics.
What conformity route applies to a Automotive ECU / telematics unit?
The route depends on the final CRA category and applicable conformity-assessment requirements. Important and critical categories can require third-party assessment or an EU cybersecurity certification scheme.
When do the CRA requirements apply?
Reporting obligations apply from 11 September 2026. The CRA's general application date is 11 December 2027. Transitional treatment for products already placed on the market depends on the facts and substantial modification.