CRARequired.com

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

Factors the rules engine reads for this fact pattern, and what each outcome means.
FactorIf trueIf falseSource
Made available on the EU marketScope questions continueLikely out of scopeF-101
Supplied in the course of a commercial activityScope questions continueLikely out of scope (or the open-source light regime)F-007
Has a direct or indirect connection to a device or networkIt is a product with digital elementsLikely out of scopeF-005
You sell it under your own name or brandYou are the manufacturerImporter or distributor obligations insteadF-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.

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Example scenarios

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

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

  1. 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 ↩
  2. 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 ↩
  3. 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 ↩
  4. 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 ↩
  5. 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 ↩
  6. F-003 The Regulation applies in full from 11 December 2027. Art. 71(2) EUR-Lex ↩

Facts v2026.09.4 · rules v2026.09.1 · page RP-012 v1 · last verified 25 September 2026 · reviewed by Claude (delegated by Ron) on 8 October 2026 · content 307b36d0c547b3d1

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.