Product class
Is a tamper-resistant microprocessor or microcontroller an important product under the CRA?
Short answer: Yes, in Class II, as a category. A tamper-resistant microprocessor or microcontroller can fall under one of 2 entries 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.
“Tamper-resistant microprocessors”
“Tamper-resistant microcontrollers”
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.
“Products with digital elements that are microprocessors with security-related functionalities referred to in Table ‘Class I’, point 13, of this Annex, including tamper evidence, resistance or response, and which additionally are designed to provide protection of AVA_VAN level 2 or 3, as set out in the Common Criteria and the Common Evaluation Methodology.”
“Products with digital elements that are microcontrollers with security-related functionalities referred to in Table ‘Class I’, point 14, of this Annex, including tamper evidence, resistance or response, and which additionally are designed to provide protection of AVA_VAN level 2 or 3, as set out in the Common Criteria and the Common Evaluation Methodology.”
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 tamper-resistant microprocessor or microcontroller sit in the CRA annexes?
See the short answer and the annex quote at the top of this page.
Does a tamper-resistant microprocessor or microcontroller 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 tamper-resistant microprocessor or microcontroller 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.