Annex III, Class I (17)
Smart home products with security functionalities
Smart locks, cameras & alarms are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. These products protect physical safety and privacy at home. Exploits translate directly into unauthorised entry or surveillance.
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 (17) · Art. 32(2)
What the annex says
Smart home products with security functionalities, including smart door locks, security cameras, baby monitoring systems and alarm systems.
Paraphrase of Annex III, Class I (17); the Official Journal text governs.
Typical products in this category
- Smart door locks
- Security and doorbell cameras
- Baby monitors
- Alarm systems and sensors
Where the boundary runs
General smart-home devices without a security function (lighting, thermostats) are default products. Professional alarm systems for commercial buildings fall here too when placed on the market.
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
- Camera streams and lock commands are the sensitive functions in the Article 3 definition of severe incident; classify incidents accordingly.
- Maintain SBOMs for firmware and mobile apps.
- Publish a plain-language support period; consumers rely on it.
- 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 smart locks, cameras & alarms product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). General smart-home devices without a security function (lighting, thermostats) are default products. Professional alarm systems for commercial buildings fall here too when placed on the market.
- 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.