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CRA conformity routes by class — and the Class I gap nobody prices in

Current to 26 August 2026 · updates land in the changelog.

Classification decides who checks your work. The CRA's conformity-assessment routes (Article 32) hang off whether a product is unlisted (“default”), important Class I or II (Annex III), or critical (Annex IV).

The routes, per class

Tier	Route
Default (not listed)	Internal control — Module A self-assessment.
Class I	Self-assessment only when applying relevant harmonised standards, common specifications or certification; otherwise a third-party route (Module B+C or Module H).
Class II	Third-party conformity assessment, always — a notified body is not avoidable.
Critical (Annex IV)	European cybersecurity certification where mandated by delegated act.

The kicker: Class I's route is theoretical today

As of our verification date, zero harmonised standards under the CRA have been cited in the Official Journal. Since Class I self-assessment is conditional on applying such standards (or common specifications or certification), Class I products currently have no practical self-assessment path — the first OJ citation switches it on, and the standards timeline currently points to around 30 October 2026, having already slipped once. Until then, a Class I product heading to market on the 2027 schedule should be budgeted as if it needed a notified body, with the standards citation treated as good news if it arrives.

Two softeners

SMEs get proportionately reduced conformity-assessment fees (Article 32(6)). And none of this touches the reporting duty: whatever your class and route, the Article 14 clocks are identical — conformity decides your path to market; reporting starts 11 September 2026 for everyone, installed base included.

Quick answers

Can Class I products under the CRA self-assess conformity?

Only when applying relevant harmonised standards, common specifications or certification. With no harmonised standards yet cited in the Official Journal at our verification date, Class I currently has no practical self-assessment path — the first citation (expected ~30 Oct 2026) changes that.

Do Class II products always need a notified body?

Yes — Class II conformity assessment is always third-party under Article 32.

Does classification change the reporting deadlines?

No. The Article 14 reporting duty applies identically across default, Class I, Class II and critical products from 11 September 2026.

General information only — not legal advice, and never a conformity assessment. Whether a specific product falls in a listed category is decided against the binding technical descriptions in Implementing Regulation (EU) 2025/2392, and reporting-platform mechanics are ENISA-published material marked subject to change. Sources are Regulation (EU) 2024/2847 (CELEX 32024R2847; Annex III/IV item texts read verbatim from EUR-Lex) and our audited kit research. © 2026 Kilde.

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