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Product classifierDefaultRegulation (EU) 2024/2847

Is a smart field device 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

smart transmitter or field instrument

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).

Smart transmitters and field instruments with a digital interface are in scope and default class — measurement is not an Annex III category.

02
Why

Why it lands in this class

HART, fieldbus, Bluetooth or Ethernet connectivity is a data connection under Article 2(1). The core function — measuring a process variable — matches no listed category.

Scope is broader than many instrument makers expect: configuration over Bluetooth or a service app counts as a connection.

“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 instrument relies on a cloud or app service you designed: that remote data processing is part of the product (Article 3(2)).
  • The device is purely analogue (4–20 mA with no digital communication and no configuration port): scope may not apply — document why.
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.

  • Which connection brings the instrument into scope, and how it is secured by default.
  • How configuration changes are authenticated, especially over short-range wireless.
  • How you will notify customers of vulnerabilities in devices with no automatic update path.

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.