Annex III, Class I (12)
Routers, modems intended for the connection to the internet, and switches
Routers, modems & switches are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Network equipment is internet-facing, long-lived, rarely updated by end users and therefore a prime target for botnets and initial access.
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 (12) · Art. 32(2)
What the annex says
Routers, modems intended for the connection to the internet, and switches.
Paraphrase of Annex III, Class I (12); the Official Journal text governs.
Typical products in this category
- Consumer and SME routers and gateways
- DSL, cable and fibre modems
- Managed and unmanaged switches with firmware
Where the boundary runs
Industrial switches and routers are in this category too; sector-specific rules (for example radio equipment under the RED) apply in parallel and the CRA coordinates with them rather than replacing them.
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
- Secure, automatic update mechanisms are an essential requirement and the single most effective mitigation; document them.
- Expect end-of-support to be scrutinised: routers stay deployed far beyond typical support windows.
- Rehearse Article 14 reporting for botnet enrolment of fielded devices — a common severe-incident pattern.
- 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 routers, modems & switches product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). Industrial switches and routers are in this category too; sector-specific rules (for example radio equipment under the RED) apply in parallel and the CRA coordinates with them rather than replacing them.
- 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.