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Annex III, Class I, point 5

Is a VPN an important product under the CRA?

Yes. Annex III Class I covers products with digital elements with the function of a virtual private network. The category is written around the function, not the product type, so a device whose VPN is one feature among many is still in it.

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

The category, quoted in full:

Products with digital elements with the function of virtual private network (VPN)

Annex III, Class I, point 5, Regulation (EU) 2024/2847

Frequently confused with:

  • Firewalls, intrusion detection and prevention systemsImportant - Class II

    Firewalls are Class II. A UTM appliance that both terminates VPN tunnels and filters traffic answers to whichever is its core functionality - recital 4 of Implementing Regulation (EU) 2025/2392 gives the router-with-firewall case and says the added functionality does not in itself change the category.

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
Firewalls & IDS/IPSAnnex III Class II point 2 covers firewalls, intrusion detection and prevention systems, and Class II makes a notified body assessment mandatory.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.