CRA compliance for Industrial controller / automation device
All other products (default class)
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 All other products (default class) means for this product
The Cyber Resilience Act applies to a wide range of products with digital elements. Products that are not on the Annex III (important) or Annex IV (critical) lists fall under the default class. Conformity is typically assessed under Module A, the manufacturer's internal control, without a notified body. The full set of Annex VII technical documentation, an EU Declaration of Conformity and the Annex I requirements still apply.
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
Module A (internal control, self-assessment)
Annex III / IV structure
Not listed in Annex III or Annex IV (Regulation (EU) 2024/2847, Art. 32(1)(a))
Products in this class are those NOT named in Annex III or Annex IV:
- No categories from Annex III or Annex IV are named for this class.
This is the Regulation's own structure (Regulation (EU) 2024/2847, Art. 32(1)(a)): everything that is not named in Annex III or Annex IV sits here. Whether a particular product is actually excluded from those annexes is the manufacturer's guided questionnaire answer, never an assumption of this site.
Key obligations
- Annex VII technical documentation for the product and its vulnerability handling
- EU Declaration of Conformity (Annex V) under the sole responsibility of the manufacturer
- Annex I essential requirements: secure by default, update mechanism, access control, data protection, incident resilience
- Annex I Part II vulnerability handling: SBOM, CVD policy, security contact, coordinated vulnerability disclosure
- Support period determination per Article 13(8) and support-period information
- Reporting actively exploited vulnerabilities and severe incidents per Article 14
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.