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Product classifierImportant — Class IRegulation (EU) 2024/2847

Is a fieldbus interface module covered by the EU Cyber Resilience Act?

The short answer, the Official Journal text behind it, and the judgment calls an assessor will test.

01
Verdict

fieldbus or industrial Ethernet interface module

In scope · Important — Class I

Scope
In scope if it has a direct or indirect data connection to a device or network (Article 2(1)) — almost every modern one does.
Class
Important — Class I — Annex III, Class I.
Route
Module A is only available if you apply harmonised standards, common specifications or a European cybersecurity certification scheme (assurance level at least ‘substantial’) in full. Otherwise a notified body is involved: EU-type examination (Module B + C) or full quality assurance (Module H) — Article 32(2).
Dates
Article 14 reporting has applied since 11 September 2026; the main obligations apply from 11 December 2027 (Article 71).

A fieldbus or industrial-Ethernet interface card sold as its own product can be an important product (Annex III, Class I — network interfaces).

02
Why

Why it lands in this class

Annex III, Class I point 10 lists ‘physical and virtual network interfaces’. The Implementing Regulation’s examples explicitly include network interface cards, controllers and adapters ‘for … Fieldbus’.

This catches OT vendors by surprise: the communication module you sell separately for a PLC rack or drive can be Class I even though the PLC or drive itself is default.

“This category includes but is not limited to wired and wireless network interface cards, controllers and adapters, such as for Wi-Fi, Ethernet, IrDA, USB, Bluetooth, NearLink, Zigbee, or Fieldbus, as well as purely virtual standalone products, such as virtual network interface cards, container network interfaces and VPN interfaces.”

— Implementing Regulation (EU) 2025/2392, Annex I, point 10 (CRA Annex III, Class I, point 10)

Source: Regulation (EU) 2024/2847 — Articles 2(1), 7(1), 32; Annexes III–IV. Implementing Regulation (EU) 2025/2392.

03
Edge cases

When the answer changes

  • The interface is only ever built into your own product and not placed on the market separately: it is an integrated component, and Article 7(1) keeps the host product out of the Class I procedures.
  • The module is a gateway that translates between protocols rather than an interface adapter: see protocol gateways.
04
Auditor view

What an assessor will ask you to show

Class decides the route. It doesn’t reduce the work: every product needs the full Annex I evidence, an Article 13 risk assessment and an Annex VII technical file.

  • Whether the module is placed on the market separately (part numbers, price list, spares) — that decides whether it is a product in its own right.
  • The conformity route for the module, which may differ from the host product’s.
  • Firmware update and vulnerability handling for the module’s protocol stack.

Already developing to IEC 62443-4-1? See which requirements map to which CRA obligations in the IEC 62443 ↔ CRA crosswalk, and check your organisation’s footing with the CRA readiness score.

Classification is step one of six.

The CRA Workbench records your core-functionality reasoning the way an assessor will read it, then carries it through risk, Annex I, conformity route, vulnerability handling and the Annex VII file — with the IEC 62443 bridge built in.

See the CRA Workbench →

This page is general information about Regulation (EU) 2024/2847 and Commission Implementing Regulation (EU) 2025/2392, not legal advice. Quoted text is from the Official Journal; the analysis around it is ours. Classification turns on your product’s actual core functionality — document your own determination and confirm it against the current official texts. The CRA Workbench produces draft documentation for expert review; it indicates the evidence needed and does not, by itself, guarantee compliance.