CRA product classification
Is a Boot manager / bootloader sold as a product covered by the EU Cyber Resilience Act?
A Boot manager / bootloader sold as a product 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 Important — Class I (Annex III, Class I, point 8). 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?
TODO(owner): verify the Commission technical description and borderline product treatment.
Boot managers (Annex III, Class I, point 8)
This classification is marked likely. TODO(owner): verify the current Commission technical description and borderline treatment before launch.
TODO(owner): verify the Commission technical description and borderline product treatment.
Borderline cases
- Is the boot manager placed on the market as a product?
What you may need to do
Module A is available only where harmonised standards, common specifications or an EU cybersecurity certification scheme are applied in full. TODO(owner): verify current OJEU citations and guidance before launch. (Art. 32(2)–(4))
- Module A (only when qualifying requirements are met)
- Module B+C
- Module H
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 Boot manager / bootloader sold as a product covered by the EU Cyber Resilience Act?
The CRA may apply to a Boot manager / bootloader sold as a product placed on the EU market as a product with digital elements, subject to the scope and exclusions. This preliminary page associates it with Annex III, Class I, point 8; confirm its intended purpose and technical characteristics.
What conformity route applies to a Boot manager / bootloader sold as a product?
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.