Annex III, Class I (2)
Standalone and embedded browsers
Browsers are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Browsers execute untrusted code from the internet by design. Their attack surface is enormous and exploited browser vulnerabilities are among the most common entries in exploitation catalogues.
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 (2) · Art. 32(2)
What the annex says
Standalone and embedded browsers.
Paraphrase of Annex III, Class I (2); the Official Journal text governs.
Typical products in this category
- Desktop and mobile web browsers
- Embedded browser engines in kiosks, infotainment and set-top boxes
- In-app browsers bundled with a product
Where the boundary runs
A product that merely renders HTML through the platform's system WebView is not itself a browser; the WebView's manufacturer is. A product that ships its own engine (Chromium, WebKit, Gecko) as an embedded browser is in scope for that component.
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
- Track the embedded engine version per product release in the SBOM; upstream security releases are frequent.
- Plan an update cadence that can follow upstream patch windows — often days, not quarters.
- Record which upstream CVEs are reachable in your embedding; unreachable ones are VEX 'not affected' with justification.
- 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 browsers product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). A product that merely renders HTML through the platform's system WebView is not itself a browser; the WebView's manufacturer is. A product that ships its own engine (Chromium, WebKit, Gecko) as an embedded browser is in scope for that component.
- 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.