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Product classifierDefaultRegulation (EU) 2024/2847

Is a protocol gateway 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 protocol gateway

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).

A protocol gateway (Modbus ↔ OPC UA, PROFIBUS ↔ PROFINET and similar) is in scope and usually default class — protocol translation is not a listed category.

02
Why

Why it lands in this class

Its core function is translating between protocols. Routing between networks by ‘selecting paths or routes using routing protocol mechanisms’ is the Class I router description; translation is a different function.

Many gateways can also route, tunnel or forward. Recital 5 of the Implementing Regulation says the ability to perform a listed function does not make it the product’s core functionality.

“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 gateway is sold as a router or cellular modem for internet connectivity with protocol conversion as a feature: Class I (routers, modems) is the stronger reading — see industrial routers.
  • The gateway’s headline function is an encrypted tunnel to a remote site: see VPN 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.

  • The written reasoning for rejecting the router and VPN categories — this is the most contested call for gateways.
  • How the gateway handles the insecure legacy protocol on one side (Annex I Part I): segmentation, allow-lists, read-only modes.
  • A vulnerability-handling process that covers the protocol stacks you licence from third parties.

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.