Regulation 2025/2392 Technical Descriptions

Regulation 2025/2392 explains the technical meaning of the important and critical product category names. It does not replace Annex III or Annex IV. It helps decide whether a product's core functionality matches one of those categories.

Technical descriptions

1. The technical description of the categories of products with digital elements under classes I and II listed in Annex III to Regulation (EU) 2024/2847 shall be as set out in Annex I to this Regulation. 2. The technical description of the categories of products with digital elements listed in Annex IV to Regulation (EU) 2024/2847 shall be as set out in the Annex II to this Regulation.

Commission Implementing Regulation (EU) 2025/2392, Article 2

The Regulation is an implementing act under Article 7(4) of the CRA. It gives the descriptions used to read the category names. It does not add a new product class, and it does not decide the conformity route by itself.

Core functionality

Pursuant to Article 7(1) and Article 8(1) of Regulation (EU) 2024/2847, the core functionality of a product with digital elements determines whether that product with digital elements meets the technical description of a category of important or critical products with digital elements and therefore the applicable conformity assessment procedures.

Commission Implementing Regulation (EU) 2025/2392, recital 2

Core functionality means the product's main function as placed on the market. A product can contain features from another category without becoming that category. The opposite is also true: extra features do not remove a product from a category if its main function still matches the description.

Embedded browser

A news app is not a browser product only because it integrates an embedded browser.

Router with firewall functions

A router can still have router core functionality even when it also includes firewall functions.

Smartphone with several functions

A smartphone is generally not classified as an operating system or password manager only because it includes those functions.

Important Class I descriptions

Annex I to Regulation 2025/2392 gives the technical descriptions for the Class I categories listed in Annex III to the CRA.

Important Class II descriptions

Class II remains an important product category, but it carries a stricter conformity-assessment effect than Class I.

Critical product descriptions

Annex II to Regulation 2025/2392 gives the technical descriptions for the critical product categories listed in Annex IV to the CRA.

Boundary examples

The examples in the recitals all point to the same rule. Classification follows the product's core functionality, not every component or capability inside the product.

Integrated component

A component can matter for security, but it does not automatically classify the product that contains it.

Similar capability

A product that can perform some SIEM-like tasks is not a SIEM if its core functionality is different.

Extra function

A product does not lose its category just because it performs additional functions outside the description.

Effect on classification

The technical description affects classification. Classification then affects the conformity-assessment route. The route details belong in Conformity Assessment.

Product classification as a whole is explained in Product Classification.

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