Annex III, Class II (2)
Firewalls, intrusion detection and prevention systems
Firewalls, IDS & IPS are important product, class ii under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. These products are the enforcement point for network security and are internet-facing; exploited firewall vulnerabilities have repeatedly enabled mass compromise. Class II requires third-party conformity assessment.
Updated 2026-09-12 · Operational guidance, not legal advice.
- Classification
- Important product — Class II
- Conformity route
- Third-party assessment required
- Reference
- Annex III, Class II (2) · Art. 32(3)
What the annex says
Firewalls, intrusion detection and prevention systems.
Paraphrase of Annex III, Class II (2); the Official Journal text governs.
Typical products in this category
- Network firewalls and next-generation firewalls
- Web application firewalls delivered as products
- Network intrusion detection and prevention systems
Where the boundary runs
Host-based endpoint protection is Class I (anti-malware). Routers with basic packet filtering are Class I (routers); products whose core function is firewalling or intrusion prevention are Class II.
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
Third-party assessment required. EU-type examination (Module B) with conformity to type (Module C), or full quality assurance (Module H), involving a notified body; alternatively a European cybersecurity certificate at assurance level 'substantial' or higher where a scheme exists. (Art. 32(3))
What to prepare operationally
- Third-party assessment applies regardless of standards used; budget for it in the product roadmap.
- Management-plane exposure is the recurring root cause in this category; document hardening and default configuration.
- Rehearse the 24-hour early warning: exploitation of these devices is usually public within hours.
- 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 firewalls, ids & ips product an important product — class ii?
- Only where the listed function is the product's core functionality (Article 7). Host-based endpoint protection is Class I (anti-malware). Routers with basic packet filtering are Class I (routers); products whose core function is firewalling or intrusion prevention are Class II.
- What changes compared with a default product?
- EU-type examination (Module B) with conformity to type (Module C), or full quality assurance (Module H), involving a notified body; alternatively a European cybersecurity certificate at assurance level 'substantial' or higher where a scheme exists. 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.