Product class
Is a firewall or intrusion detection system an important product under the CRA?
Short answer: Yes, in Class II, as a category. A firewall or intrusion detection system is listed in Annex III, Class II. 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. Class II has its own conformity route under Article 32(3), set out below.
“Firewalls, intrusion detection and prevention systems”
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.
“Firewalls are products with digital elements that protect a connected network or system from unauthorized access by monitoring and restricting data communication traffic to and from that network.
This category includes but is not limited to network firewalls and application firewalls such as web application firewalls or filters and anti-spam gateways.
Intrusion detection systems are products with digital elements that monitor traffic once it has entered the network environment for suspicious activity and detect or identify that an intrusion has been attempted, is occurring, or has occurred on a connected network or system.
This category includes but is not limited to network-based intrusion detection systems and host-based intrusion detection systems.
Intrusion prevention systems are products with digital elements composed of an intrusion detection system that actively responds to an intrusion to a connected network or system.
This category includes but is not limited to network-based intrusion prevention systems and host-based intrusion prevention systems.”
What Class II means for the conformity route
Article 32(3): conformity is demonstrated through EU-type examination followed by conformity to EU-type based on internal production control (module B+C), through full quality assurance (module H), or, where available and applicable, through a European cybersecurity certification scheme at assurance level at least 'substantial'. The first two run through a notified body.
The wording of Article 32(3) 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 firewall or intrusion detection system sit in the CRA annexes?
See the short answer and the annex quote at the top of this page.
Does a firewall or intrusion detection system need a notified body?
Not on every route: under Article 32(3), the first two procedures run through a notified body and the certification scheme option does not, as the route section above sets out.
When do the CRA rules for a firewall or intrusion detection system 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.