Annex III, Class I (8)

Boot managers

Boot managers are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Code that runs before the operating system can defeat every protection above it; boot-level compromise is persistent and hard to detect.

Updated 2026-09-12 · Operational guidance, not legal advice.

Classification
Important product — Class I
Conformity route
Self-assessment only with fully applied standards
Reference
Annex III, Class I (8) · Art. 32(2)

What the annex says

Boot managers.

Paraphrase of Annex III, Class I (8); the Official Journal text governs.

Typical products in this category

  • UEFI boot loaders and shims
  • Embedded bootloaders shipped as products
  • Secure-boot management software

Where the boundary runs

A device manufacturer integrating a third-party bootloader classifies the device by its own core function; the bootloader's manufacturer carries the Class I obligations for the bootloader as a product.

The test is core functionality (Article 7). Record the reasoning and the approver: the category determines the conformity assessment route and market surveillance authorities can challenge it.

Conformity assessment

Self-assessment only with fully applied standards. Module A is permitted only where harmonised standards, common specifications or a European cybersecurity certification scheme are applied in full; otherwise EU-type examination (Module B) followed by conformity to type (Module C), or full quality assurance (Module H). (Art. 32(2))

What to prepare operationally

  1. Maintain signing-key custody documentation and revocation procedures (dbx-style) in the technical file.
  2. Keep an SBOM even for small firmware components; bootloaders reuse cryptographic libraries with known CVEs.
  3. Define how a security update reaches devices already in the field.
  4. Maintain an SBOM per released version, match it continuously against vulnerability intelligence, and keep the Article 14 runbook rehearsed — these apply to every product with digital elements, listed or not.

Frequently asked

Is every boot managers product an important product — class i?
Only where the listed function is the product's core functionality (Article 7). A device manufacturer integrating a third-party bootloader classifies the device by its own core function; the bootloader's manufacturer carries the Class I obligations for the bootloader as a product.
What changes compared with a default product?
Module A is permitted only where harmonised standards, common specifications or a European cybersecurity certification scheme are applied in full; otherwise EU-type examination (Module B) followed by conformity to type (Module C), or full quality assurance (Module H). The essential requirements of Annex I, the vulnerability-handling duties and Article 14 reporting apply to every product with digital elements regardless of category.
From when?
Article 14 reporting obligations have applied to all manufacturers since 11 September 2026. Conformity assessment and CE marking under the CRA apply from 11 December 2027; products placed on the market before that date are not required to be re-assessed unless substantially modified.

Other important product — class i categories

Classify it in Vellaci — with reasoning on record.

The onboarding classifier asks which listed functions your product provides and whether they are core, cites the annex, and stores the approved decision on the product.