CRA product classification
Is a Firmware or software component sold separately covered by the EU Cyber Resilience Act?
A Firmware or software component sold separately 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?
TODO(owner): verify product-boundary and placing-on-market treatment.
This classification is marked likely. TODO(owner): verify the current Commission technical description and borderline treatment before launch.
TODO(owner): verify product-boundary and placing-on-market treatment.
Borderline cases
This starter classification has no additional product-specific follow-up configured. Exclusions and intended purpose still affect the final outcome.
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 Firmware or software component sold separately covered by the EU Cyber Resilience Act?
The CRA may apply to a Firmware or software component sold separately 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 Firmware or software component sold separately?
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.