Annex III, Class I (10)
Physical and virtual network interfaces
Network interfaces are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Interfaces process every packet before the host sees it and run firmware with DMA access; a flaw grants a foothold below the operating system.
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 (10) · Art. 32(2)
What the annex says
Physical and virtual network interfaces.
Paraphrase of Annex III, Class I (10); the Official Journal text governs.
Typical products in this category
- Network interface cards with firmware
- SmartNICs and DPUs
- Virtual NIC drivers and paravirtualised interfaces shipped as products
Where the boundary runs
A host device that contains a NIC is classified by its own function; the NIC's manufacturer holds the Class I obligations for the NIC 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
- Ship firmware SBOMs and a firmware update path that customers can actually operate.
- Document offload features and their security boundaries in the technical file.
- Coordinate disclosures with OEMs who integrate the interface into their systems.
- 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 network interfaces product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). A host device that contains a NIC is classified by its own function; the NIC's manufacturer holds the Class I obligations for the NIC 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.