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Product classifierImportant — Class IRegulation (EU) 2024/2847

Is a remote-access VPN 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

secure remote-access / VPN gateway

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 remote-access or VPN gateway is an important product (Annex III, Class I).

02
Why

Why it lands in this class

Annex III, Class I point 5 covers ‘products with digital elements with the function of virtual private network (VPN)’. The Implementing Regulation names VPN gateways explicitly.

OT remote-access appliances — the box that lets a machine builder reach an installed line — usually have tunnelling as their core function.

“Products with digital elements that establish an encrypted logical tunnel that is constructed from the system resources of a physical or virtual network. This category includes but is not limited to virtual private network clients, virtual private network servers and virtual private network gateways.”

— Implementing Regulation (EU) 2025/2392, Annex I, point 5 (CRA Annex III, Class I, point 5)

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 VPN is a feature inside a PLC, HMI or RTU rather than the product’s purpose: Article 7(1) — integration does not by itself make the host product Class I.
  • The appliance also enforces firewall policy as a core function: read the firewall description (Class II), which has a stricter route.
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 and, if you are claiming Module A, the standard or scheme you apply in full.
  • Authentication strength and session control for third-party remote access.
  • How the vendor-hosted rendezvous or cloud service is covered as remote data processing.

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.