Product class
Is a connected toy an important product under the CRA?
Short answer: Yes, as a category. A connected toy is listed in Annex III, Class I, item 18. Under Article 7(1), a product whose core functionality is that of a listed category is an important product, so whether your product is one depends on its core functionality.
“Internet connected toys covered by Directive 2009/48/EC”
Technical description
Commission Implementing Regulation (EU) 2025/2392 gives the technical description of each category in the annexes. It says what the category covers, in the Official Journal's words.
“Internet connected toys that have social interactive features are products with digital elements that are covered by Directive 2009/48/EC, that communicate on the public Internet, whether directly or via any other equipment, and that have embedded technologies that enable inbound and outbound communication, such as keyboard, microphone, speaker or camera.
Internet connected toys that have location tracking features are products with digital elements that are covered by Directive 2009/48/EC, that communicate on the public Internet, whether directly or via any other equipment, and that have technologies that enable tracking or inferring of the geographical location of the toy or its user. Where the toy merely detects the proximity of the user or of other toys by using sensing technologies, the toy is not to be considered to have location tracking features.”
What Class I means for the conformity route
Article 32(2) caveat: self-assessment via internal control remains available only if you apply in full harmonised standards, common specifications or European cybersecurity certification schemes at assurance level at least 'substantial'; where you apply them only in part or not at all, or none exist, EU-type examination followed by production control (module B+C) or full quality assurance (module H) applies.
The wording of Article 32(2) is quoted in the product classes guide.
When it applies
Since 11 June 2026, the rules on notified conformity assessment bodies, Chapter IV (Articles 35 to 51), have applied. The reporting duties of Article 14 have applied since 11 September 2026. The CRA will apply in full from 11 December 2027. The wording of the application clause is quoted in the product classes guide.
Edge cases
- Free and open-source software. Article 32(5) has its own rule for Annex III products. The wording of Article 32(5) is quoted in the product classes guide.
- The core functionality decides. Check your product's core functionality against the annex text quoted above. The wording of Article 7(1) is quoted in the product classes guide.
Questions and answers
Where does a connected toy sit in the CRA annexes?
See the short answer and the annex quote at the top of this page.
Does a connected toy need a notified body?
Not in every case: internal control stays open only where the Article 32(2) conditions are met, as the route section above sets out.
When do the CRA rules for a connected toy apply?
Reporting duties under Article 14 have applied since 11 September 2026, and the CRA will apply in full from 11 December 2027.
Cybiq checks the CRA only. Orientation, not legal advice. Quoted spans come from Regulation (EU) 2024/2847 as published in the Official Journal and are re-verified against the live text by automated tests. Verify before relying on any item; for an assessment of your own product, consult a qualified lawyer.