EU Cyber Resilience Act Product Scope FAQ

The CRA applies to any "product with digital elements" (PDE) sold on the EU market whose intended or reasonably foreseeable use includes a direct or indirect connection to a device or network — hardware, software, and components alike. The following is a list of impacted product categories. The exclusions listed are defined in Article 2 of Regulation (EU) 2024/2847 and reflect sectors already governed by equivalent EU cybersecurity legislation.

Product CategoryIn Scope?Notes
IoT devices (smart home cameras, thermostats, doorbells, etc.)✅ In ScopeCore target of the CRA; network connectivity is inherent
Consumer electronics (smart TVs, tablets, wearables, fitness trackers)✅ In ScopeCovered if capable of connecting to a device or network
Industrial control systems & OT devices (PLCs, SCADA, sensors with connectivity)✅ In ScopeIncludes IIoT and connected factory equipment
Networking equipment (routers, switches, firewalls, modems)✅ In ScopeOften classified as Important or Critical under Annex III
Software products (desktop apps, mobile apps, operating systems)✅ In ScopeApplies to standalone software placed on the market commercially
Remote data processing solutions (manufacturer-operated cloud backends required for product function)✅ In ScopeIn scope only when designed by the manufacturer and required for the product to function
Hardware components sold separately (microcontrollers, chipsets, modules)✅ In ScopeComponents placed on the market independently are covered
Connected toys & children's products✅ In ScopeExplicitly cited by the European Commission as a primary use case
Payment terminals & devices handling financial data✅ In ScopeMay fall into stricter Important or Critical classification tiers
Medical devices & in vitro diagnostic devices❌ ExcludedGoverned by EU MDR (2017/745) and IVDR (2017/746), which already impose cybersecurity lifecycle requirements
Motor vehicles & automotive systems❌ ExcludedCovered by Regulation (EU) 2019/2144 and UNECE vehicle cybersecurity rules; note: components sold separately outside this regime may remain in scope
Civil aviation products❌ ExcludedCertified under Regulation (EU) 2018/1139 (EASA framework)
Marine equipment❌ ExcludedFalls under Marine Equipment Directive 2014/90/EU
National defense & national security products❌ ExcludedMust be developed or modified exclusively for defense/security purposes; dual-use products remain in scope
Non-commercial open-source software❌ ExcludedSoftware developed and distributed outside any commercial activity is out of scope; open-source integrated into a commercial product is covered under the manufacturer's obligations
Products not placed on the EU market (internal use, R&D prototypes)❌ ExcludedProducts not supplied in the course of a commercial activity fall outside scope
Identical spare parts (replacing components to same specification)❌ ExcludedNarrow exclusion under Article 2(6); any deviation from identical specs removes this exemption
Pure SaaS / cloud services (not tied to a specific product's functionality)❌ ExcludedStandalone cloud services without a connected PDE fall outside scope; may be subject to NIS2 instead

Scope determination requires product-by-product analysis. Some categories — particularly automotive components sold independently, open-source software used in commercial products, and cloud services linked to a hardware device — require careful review.

If you're unsure whether your products are in scope, contact the BG Networks team.

Recent Related Stories

EU CRA Frequently Asked Questions (FAQs)
Many companies still have questions about the EU Cyber Resilience Act and whether it applies to their products. We've compiled…
Read More