Annex III, Class II (3)

Tamper-resistant microprocessors

Tamper-resistant MPUs are important product, class ii under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Tamper resistance is a claim about physical and logical attack resistance; the market relies on it for payment, identity and infrastructure. 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 (3) · Art. 32(3)

What the annex says

Tamper-resistant microprocessors.

Paraphrase of Annex III, Class II (3); the Official Journal text governs.

Typical products in this category

  • Processors with physical tamper detection and response
  • Security co-processors for payment and identity terminals

Where the boundary runs

Microprocessors with security-related functionality but without tamper resistance are Class I. Smartcards and secure elements are Annex IV critical.

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

  1. Existing certifications (Common Criteria, EMVCo) inform but do not replace CRA conformity assessment until schemes are recognised.
  2. Document the threat model for physical attacks in the technical file.
  3. Coordinate advisories with downstream terminal and device manufacturers.
  4. 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 tamper-resistant mpus product an important product — class ii?
Only where the listed function is the product's core functionality (Article 7). Microprocessors with security-related functionality but without tamper resistance are Class I. Smartcards and secure elements are Annex IV critical.
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.

Other important product — class ii categories

Classify it in Vellaci — with reasoning on record.

The onboarding classifier asks which listed functions your product provides and whether they are core, cites the annex, and stores the approved decision on the product.