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Product classifierImportant — Class IRegulation (EU) 2024/2847

Is an industrial router 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

industrial or cellular router

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).

Industrial routers and cellular modems for internet connection are important products (Annex III, Class I).

02
Why

Why it lands in this class

Annex III, Class I point 12 lists routers and ‘modems intended for the connection to the internet’. The Implementing Regulation includes cellular modems and ‘routers with or without modems’.

An industrial cellular router used for remote connectivity to a plant or substation is a textbook match.

“Routers are products with digital elements that establish and control the flow of data between different networks by selecting paths or routes using routing protocol mechanisms and algorithms, typically operating at the network layer. This category includes but is not limited to wired and wireless routers, virtual routers and routers with or without modems.”

— Implementing Regulation (EU) 2025/2392, Annex I, point 12 (CRA Annex III, Class I, point 12)

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

  • Routing is incidental and the product’s core function is something else (protocol translation, control, telemetry): recital 5 — the ability to route is not the core function. See protocol gateways and RTUs.
  • The router’s headline function is VPN termination: it is Class I either way, but document both categories.
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 conformity route: full application of a harmonised standard or scheme (Module A) versus a notified body (Module B + C or H).
  • Secure defaults for remote management, cellular APN and exposed services.
  • How you will meet the Article 14 reporting duties for a product that is, by design, internet-facing.

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.