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Annex III, Class I, point 2

Is a web browser an important product under the CRA?

Yes. Annex III Class I covers standalone and embedded browsers. The word embedded is doing real work: a browser engine shipped inside another product is in the category on its own account.

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

The category, quoted in full:

Standalone and embedded browsers

Annex III, Class I, point 2, Regulation (EU) 2024/2847

Embedding a browser engine in something else does not make that something else a browser. Implementing Regulation (EU) 2025/2392 recital 3 says a browser engine used as a component of a news app does not in itself make the news app subject to the browser category. The integrator still has to secure the whole product; it is simply not reclassified into this category.

Frequently confused with:

  • Operating systemsImportant - Class I

    Operating systems are point 11. Recital 4 of Implementing Regulation (EU) 2025/2392 uses this exact pair: an operating system integrating browser functionality still has the core functionality of an operating system. It is not reclassified, and it does not become two products.

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
Operating systemsOperating systems are named in Annex III Class I with no qualifier, so a general-purpose, embedded or real-time OS is an important product.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.