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Annex III, Class I, point 18

Are internet connected toys covered by the CRA?

Only some. Annex III Class I point 18 covers connected toys under Directive 2009/48/EC that have social interactive features or location tracking features. A connected toy with neither is not in this category.

ClassImportant - Class I
What that class requiresSelf-assessment only if harmonised standards applied; else notified body

The category, quoted in full:

Internet connected toys covered by Directive 2009/48/EC of the European Parliament and of the Council that have social interactive features (e.g. speaking or filming) or that have location tracking features

Annex III, Class I, point 18, Regulation (EU) 2024/2847

Two qualifiers have to be checked, not one: the toy must fall under the Toy Safety Directive, and it must have social interactive or location-tracking features. The annex gives speaking or filming as examples of the first.

Frequently confused with:

Obligations that apply to every product in scope, whatever its class:

  • Essential requirements (Annex I) - secure by design & default
  • Machine-readable SBOM
  • Coordinated vulnerability disclosure policy
  • Security updates across support period (~5 yrs)
  • Technical documentation (Annex VII)
  • Conformity assessment (route depends on class)
  • CE marking + EU Declaration of Conformity
  • 24h / 72h reporting to ENISA + CSIRT (from Sep 2026)

What a manufacturer is assessed against:

  1. Cybersecurity risk assessment Art 13(2)
  2. Secure-by-design essential requirements Annex I Pt I
  3. Vulnerability-handling process Annex I Pt II
  4. Software bill of materials (SBOM) Annex I Pt II §1
  5. Coordinated vulnerability disclosure policy Art 13 · Annex I Pt II
  6. Security updates & support period Art 13(8)
  7. Technical documentation (Annex VII) Annex VII
  8. Conformity assessment & EU Declaration of Conformity Art 28 · Annex V
  9. CE marking Art 30
  10. Vulnerability & incident reporting readiness Art 14 (from 11 Sep 2026)
  11. Economic-operator & market-surveillance obligations Art 13/19–24 · Annex II

The dates that matter:

  • 11 September 2026 - reporting obligations for actively exploited vulnerabilities and severe incidents apply.
  • 11 December 2027 - full compliance applies.
  • Market-surveillance authorities can order corrective action, withdrawal or recall, and fines reach €15 million or 2.5% of global annual turnover.

Check your own products against this

The same rulebook that produced this page runs the free check. It reads your products, classifies each one against Annex III and IV, and gives you an indicative verdict with the reasoning and citation for every product.

All categories
Personal wearablesAnnex III Class I point 19 covers health-monitoring wearables to which the medical device regulations do not apply, and wearables intended for children.Product classificationWhich class each Annex III and IV category falls in, quoted from the regulation, with the conformity route it carries and the categories it is most often confused with.MethodologyThe versioned methodology behind every verdict: the six-step scoping flow, the four product classes, the eleven readiness checkpoints, and the Article each rests on.

Indicative assessment - not legal advice and not a conformity assessment.