CRA compliance for Industrial controller / automation device
Critical class (Annex IV)
About CRA compliance for Industrial controller / automation device
An industrial controller runs production logic on plant networks and often has a long operational life. CRA documentation has to reflect both the controller firmware and the support period decision, which for long-lived industrial equipment is usually longer than for consumer devices. The Annex I focus is availability and integrity of control functions.
What the Critical class (Annex IV) means for this product
Critical products are listed in Annex IV and are subject to the strictest conformity assessment routes under Article 47 and Annex VIII, always with third-party involvement. The technical documentation and its traceability are central because the notified body's examination and subsequent surveillance rest on them.
Where this device type sits in the Regulation
In the Regulation's own structure, an industrial automation controller is NOT named in Annex III or Annex IV, so it would fall in the default class under Art. 32(1)(a) (Regulation (EU) 2024/2847), unless a specific product matches a named category for another reason. Whether THIS specific controller is actually outside the annexes is the manufacturer's guided questionnaire answer, never an assumption of this site.
Conformity assessment
EU-type examination + conformity based on full quality assurance (Module H), notified body required
Annex III / IV structure
Annex IV (critical) (Regulation (EU) 2024/2847, Art. 47)
The Regulation's own structure names these 3 items in Annex IV:
- hardware devices with security boxes
- smart meter gateways and other advanced security purpose devices for secure cryptographic processing
- smartcards and similar devices, including secure elements
This is the Regulation's own structure (Regulation (EU) 2024/2847, Annex IV), not an assessment of any specific product. Whether a particular product falls within a named item is the manufacturer's guided questionnaire answer, never an assumption of this site.
Key obligations
- Strictest conformity assessment route under Article 47 and Annex VIII
- Notified body examination of the type and full quality assurance of production
- Annex VII technical documentation is the examination basis; traceability is mandatory
- Regular surveillance by the notified body for the certified type
Typical components to document (SBOM)
PLC runtimeFieldbus stackControl logicIndustrial protocol stack
Relevant Annex I requirements
I.2(h)— availability of essential control functions after an incidentI.2(f)— integrity of control commands and configurationI.2(k)— reduce the impact of an incident on the controlled process
Get the compliance document set
Annex VII technical documentation, EU DoC and the Annex I checklist, generated from your product's SBOM. Leave an email and we will send it when the generator is open.