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Guide · Product Classification

CRA Product Classification: 38% of SMEs Expect Trouble

The very first CRA question — “which class does my product fall into?” — trips up more than a third of SMEs surveyed by ENISA. The wrong answer decides whether you self-assess or need a notified body. This guide explains the three classes, quotes the survey data, and hands you a free 12-question wizard that returns a deterministic answer.

38%
of SMEs expect trouble classifying their products

Product classification is ranked among the challenges alongside understanding documentation (66%) and conformity assessment (66%).

Source: ENISA SME CRA Survey 2026, Section 1.2 (p. 11), Table 6 (p. 19) and Table 8 (p. 20).

20%
of SMEs are unsure whether they even fall in scope of the CRA

Uncertainty is highest among importers, distributors and service providers — for whom scope depends on how the supply chain is set up.

51%
of SMEs explicitly asked ENISA for classification guidance

This page and the free wizard exist because CRA studio users repeated the same question.

The three CRA classes at a glance

The class decides your conformity assessment route — from self-declaration to full quality-assurance audit by a notified body.

  • Default class

    General-purpose products with digital elements — the majority. Conformity is via self-assessment (Module A). You still comply with Annex I, but you certify yourself.

  • Class I — Important Products (Annex III, Part I)

    Higher risk categories such as password managers, identity management, browsers, VPN clients and IoT firmware. Requires application of a harmonised standard or third-party conformity assessment.

  • Class II — Critical Products (Annex III, Part II)

    Highest-risk categories such as hardware security modules, smart-meter gateways and firewalls for industrial use. Requires third-party conformity assessment by a notified body.

  • Critical products (Article 8)

    A separate class defined by delegated act — currently including hardware devices with security boxes, smart meters and smart-card readers — subject to European cybersecurity certification schemes.

How CRA Studio closes the gap

A deterministic 12-question wizard for anonymous visitors, and a persistent product-record with change history for registered users.

Free, no login

Answer 12 yes/no questions about your product's function, target audience and connectivity. The wizard returns Default, Class I or Class II with the exact Annex III reference that triggered the answer.

Registered plan value

Store the classification per product, track changes over time (e.g. when a feature moves you from Default to Class I), and attach the outcome to the product's compliance dossier so your team and auditor see the same source of truth.