CRA compliance for Network router
All other products (default class)
About CRA compliance for Network router
A router is a high-value target because it sits at the network edge. Its CRA documentation has to cover the network stack, the management interface and the update mechanism, and the risk assessment has to reflect that a compromise of the device compromises the whole network behind it.
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, 'routers, modems and switches intended for connection to the internet' are named in Annex III Class I (Regulation (EU) 2024/2847, Art. 32(2)). Whether THIS specific router is caught by that named category 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)
Linux kernelWi-Fi driverVPN / firewall stackWeb management UITLS library
Relevant Annex I requirements
I.2(j)— limit the attack surface of the management interfaceI.2(c)— timely security updates for the router firmwareI.2(i)— minimise negative impact on other devices and networks
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.