CRA compliance for IoT sensor
All other products (default class)
About CRA compliance for IoT sensor
An IoT sensor collects measurement data and transmits it over a network. Its attack surface is small but real: firmware update path, wireless communication, and any stored configuration. The CRA documentation set for a sensor is comparatively light, which makes it a fast demonstration of the motor: SBOM, a short Annex VII file, and the Annex I checklist.
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, a generic sensing device 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 sensor 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)
Sensor driverWireless stack (BLE / Zigbee / LoRa)Low-power MCU firmwareTLS library
Relevant Annex I requirements
I.2(e)— encrypt the transmitted measurement dataI.2(c)— a reliable, user-notified firmware update pathII.1— document components in a machine-readable SBOM
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.