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Product classifierDefaultRegulation (EU) 2024/2847

Is an HMI 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

HMI operator panel

In scope · Default class

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
Default — Not in Annex III or IV.
Route
Self-assessment is available: internal control (Module A, Annex VIII) under Article 32(1). No notified body is needed, but the full Annex I evidence and the Annex VII technical file still are.
Dates
Article 14 reporting has applied since 11 September 2026; the main obligations apply from 11 December 2027 (Article 71).

An HMI panel is in scope and usually default class — its core function is operator visualisation, which no Annex III category names.

02
Why

Why it lands in this class

The core function of an HMI is presenting process data and taking operator input. Annex III lists browsers, operating systems and remote-access (VPN) products, but an HMI that merely contains a browser engine or an OS is not one of those products — Article 7(1), second sentence.

HMIs typically carry more attack surface than PLCs: a full OS, a web server, remote-operation features, USB. That doesn’t change the class, but it drives how much Annex I evidence you need.

“a product with digital elements that has the ability to perform the functions of a product category set out in Annexes III and IV to Regulation (EU) 2024/2847 but whose core functionality itself is different from that of such product category is not to be considered to meet the technical description of that product category.”

— Implementing Regulation (EU) 2025/2392, recital 5

“The integration of a product with digital elements which has the core functionality of a product category set out in Annex III shall not in itself render the product in which it is integrated subject to the conformity assessment procedures referred to in Article 32(2) and (3).”

— Regulation (EU) 2024/2847, Article 7(1)

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 product is really a remote-access gateway with a screen attached — if secure remote access is the core function, read the VPN gateway page.
  • You ship the HMI runtime as standalone software on a customer PC: it is still a product with digital elements, still default unless its core function matches a category.
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.

  • The core-function statement, with the embedded OS, browser and remote-access server listed as integrated components.
  • Secure-by-default settings for the remote-operation features (Annex I Part I) — what is off out of the box.
  • How OS vulnerabilities in the panel image are tracked and patched through the support period (Annex I Part II).

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.