Product class
Is a router, modem or switch an important product under the CRA?
Short answer: Yes, as a category. A router, modem or switch can fall under one of 2 entries in Annex III, Class I. 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.
“Physical and virtual network interfaces”
“Routers, modems intended for the connection to the internet, and switches”
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.
“Physical network interfaces are products with digital elements that directly connect a device to a network via an application programming interface (API) provided by the interface drivers, typically operating at the data link layer, and that feature hardware adapters to transmission media with corresponding firmware, typically operating at the physical and data link layer.
Virtual network interfaces are products with digital elements that directly or indirectly connect a device to a network via an API that emulates that of drivers of physical network interfaces, typically operating at the data link layer.
This category includes but is not limited to wired and wireless network interface cards, controllers and adapters, such as for Wi-Fi, Ethernet, IrDA, USB, Bluetooth, NearLink, Zigbee, or Fieldbus, as well as purely virtual standalone products, such as virtual network interface cards, container network interfaces and VPN interfaces.”
“Routers are products with digital elements that establish and control the flow of data between different networks by selecting paths or routes using routing protocol mechanisms and algorithms, typically operating at the network layer.
This category includes but is not limited to wired and wireless routers, virtual routers and routers with or without modems.
Modems intended for the connection to the Internet are hardware products with digital elements that use digital modulation and demodulation techniques to convert analogue signals from and to digital signals for IP-based communication.
This category includes but is not limited to fibre modems, Digital Subscriber Line (DSL) modems, cable (DOCSIS) modems, satellite modems and cellular modems.
Switches are products with digital elements that provide connectivity between networked devices through packet forwarding mechanisms and that have a management plane, typically implemented at the data link or network layer.
This category includes but is not limited to managed switches, smart switches, multilayer switches, virtual security switches, programmable switches for software-defined networking and bridges such as wireless access points.”
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 router, modem or switch sit in the CRA annexes?
See the short answer and the annex quote at the top of this page.
Does a router, modem or switch 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 router, modem or switch 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.