Does the CRA apply to routers?
Likely yes
Likely yes. A router or switch is connected hardware with embedded software, made available in the EU in the course of a commercial activity: a product with digital elements [[F-005]] [[F-007]]. Whether it falls in an important or critical class is a question for the full determination, not this page.
The deciding factors
| Factor | If true | If false | Source |
|---|---|---|---|
| Made available on the EU market | Scope questions continue | Likely out of scope | F-101 |
| Supplied in the course of a commercial activity | Scope questions continue | Likely out of scope (or the open-source light regime) | F-007 |
| Has a direct or indirect connection to a device or network | It is a product with digital elements | Likely out of scope | F-005 |
| You sell it under your own name or brand | You are the manufacturer | Importer or distributor obligations instead | F-106 |
Check your own product
Start the short scope check with the product type pre-selected. Every legally material fact — EU availability, commercial activity, exclusions, your role — is asked, never assumed.
Example scenarios
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Consumer Wi-Fi router sold through EU electronics retailers
Likely in scope · role: _
Connected hardware sold commercially: a product with digital elements in scope.
Deciding fact: Art. 3(1), Art. 2(1)
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ISP-branded router manufactured by a contract supplier
Likely in scope · role: _
The ISP markets the router under its own brand and is the manufacturer for the Regulation's purposes.
Deciding fact: Art. 3(1), Art. 2(1)
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EU distributor reselling a non-EU brand's switches
In scope — operator obligations differ by role · role: _
The switch is in scope; a distributor holds due-care obligations rather than manufacturer ones.
Deciding fact: Art. 3(1), Art. 2(1)
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Router component type-approved as part of a vehicle
Likely out of scope · role: _
Products type-approved under the motor-vehicle regulation are excluded from this Regulation.
Deciding fact: Art. 2(2)–(4), (6)–(7)
Each scenario is a fixture: the shared CEMarque rules engine evaluates its inputs at build time and the page cannot be served if the outcome shown here differs from the engine's.
Edge cases
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Why
Network equipment is the clearest case
A router exists to connect devices to networks, so the connection element of the definition of a product with digital elements is met without argument [1]. Sold commercially in the EU, it is in scope [2] [3].
Applicability, not class
This page answers whether the Regulation applies. It does not say which class the product falls in or which conformity route follows; that depends on the product's function and is determined in the full check on CEMarque. Applicability is the same regardless of class [1].
Brands, importers and distributors
Marketing a product under your own name or trademark makes you the manufacturer even if someone else developed it, which is why ISP-branded routers make the ISP the manufacturer [4]. A business bringing another brand's equipment into the EU is an importer, and one reselling within the EU is a distributor; the scope check reports that role.
Exclusions and timing
Type-approved motor-vehicle products and certain aviation, marine and defence cases are excluded, so a router embedded in such a product follows its own regime [5]. The Regulation applies in full from 11 December 2027 [6].
Timing
Article 14 reporting applies from 2026-09-11; full requirements and CE marking apply from 2027-12-11. Dates come from the Facts Table entries cited below, evaluated for the first example; run the check for your own product's dates.
What to do next
CRARequired only answers applicability. CEMarque carries your answers forward and adds your role, class, conformity route, dates, obligations, and a permanent cited verdict.
Check my product Run the full cited determination on CEMarque
Related applicability questions
Sources
- F-005 A product with digital elements is a software or hardware product and its remote data processing solutions, including components placed on the market separately, whose intended purpose or reasonably foreseeable use includes a direct or indirect logical or physical data connection to a device or network. Art. 3(1), Art. 2(1) EUR-Lex ↩
- F-007 The Regulation applies to products made available on the market in the course of a commercial activity; charging a price, charging for support, monetising via advertising or data, or otherwise intending to monetise are commercial activity. Art. 2(1), Art. 3(22), Recitals EUR-Lex ↩
- F-101 Made available on the market means supply for distribution or use on the EU market in the course of a commercial activity. Art. 3(22) EUR-Lex ↩
- F-106 Marketing a product under your own name or trademark makes you the manufacturer even if someone else developed it. Art. 3(13), Art. 21 EUR-Lex ↩
- F-010 Excluded: medical devices (Regulation (EU) 2017/745) and in vitro diagnostics (2017/746) and motor-vehicle type-approved products (2019/2144) (Art. 2(2)); civil aviation products certified under Regulation (EU) 2018/1139 (Art. 2(3)); marine equipment under Directive 2014/90/EU (Art. 2(4)); spare parts made to identical specifications (Art. 2(6)); products developed or modified exclusively for national security or defence, or designed exclusively to process classified information (Art. 2(7)). Art. 2(2)–(4), (6)–(7) EUR-Lex ↩
- F-003 The Regulation applies in full from 11 December 2027. Art. 71(2) EUR-Lex ↩
CRARequired answers applicability only, using scope logic and cited regulatory facts maintained by CEMarque, which encodes Regulation (EU) 2024/2847 and published guidance as of Facts v2026.09.4 (10 September 2026). Results are "likely" or "conditional" readings of your answers, not a legal opinion and not a conformity assessment. Run the full cited determination on CEMarque before you act. Methodology.