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Product classifierImportant — Class IRegulation (EU) 2024/2847

Is a managed industrial switch 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

managed industrial Ethernet switch

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 managed industrial switch is an important product (Annex III, Class I). An unmanaged switch is not in that category.

02
Why

Why it lands in this class

Annex III, Class I point 12 lists ‘routers, modems intended for the connection to the internet, and switches’. The Implementing Regulation defines switches as providing connectivity through packet forwarding and that have a management plane.

That qualifier matters in OT: a managed switch (web UI, SNMP, CLI, VLAN configuration) matches the description; an unmanaged switch with no management plane does not, and falls back to the default class.

“Switches are products with digital elements that provide connectivity between networked devices through packet forwarding mechanisms and that have a management plane, typically implemented at the data link or network layer. This category includes but is not limited to managed switches, smart switches, multilayer switches, virtual security switches, programmable switches for software-defined networking and bridges such as wireless access points.”

— 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

  • The switch has no management interface at all: default class — record the absence of a management plane as the reason.
  • The switch also routes or filters traffic as its core function (a layer-3 security switch): check the router (Class I) and firewall (Class II) descriptions.
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 you are applying a harmonised standard or certification scheme in full — that decides whether Module A is available or a notified body is needed.
  • Secure defaults for the management plane: default credentials, enabled services, management VLAN.
  • Firmware signing and update delivery for switches that stay in service for a decade or more.

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.

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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.