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

Is a VPN product an important product under the CRA?

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Important product, Class I (Annex III Class I (5), Art. 7(1))

Yes, most likely. The CRA lists "products with digital elements with the function of virtual private network (VPN)" as important products (Annex III, Class I, item 5). A product whose core functionality is providing a VPN carries the full manufacturer obligations and a restricted conformity route: self-assessment stays available only where harmonised standards, common specifications, or eligible certification are applied in full. A VPN feature bolted onto a product that does something else is a different question, decided on core functionality.

Basis: Annex III Class I (5), Art. 7(1), Art. 32(1)-(2)

Judgment call: Whether a product "has the core functionality of" a VPN, as opposed to including a VPN feature, is a classification judgment. The technical descriptions in Implementing Regulation (EU) 2025/2392 control.

How the CRA describes VPNs Annex III Class I (5), Art. 7(1), Art. 7(2), Art. 7(4)

Item 5 of Class I reads "products with digital elements with the function of virtual private network (VPN)". A consumer VPN app, a corporate VPN client, a VPN concentrator or gateway appliance, and the firmware in a VPN box all sit inside the category where providing the VPN is what the product is for.

It lands in Class I for the reason Article 7(2) gives: products that primarily perform functions critical to the cybersecurity of other products, such as network protection, are treated as important. The plain label is only the starting point; the binding scope is the technical description in the implementing act.

A VPN product versus a product with a VPN feature Art. 7(1), Art. 7(4)

The recurring question is the difference between a VPN product and a product that happens to include VPN connectivity. A router that offers a VPN passthrough, an operating system with a built-in VPN client, or an enterprise suite with a VPN module raises the question of whether the VPN is its core functionality or one feature among many.

Article 7(1) settles the general principle: integrating a component with the core functionality of a listed category does not, in itself, make the surrounding product one of those categories. So a router stays a router, judged on its own listing, and a dedicated VPN client is a VPN product. Resolve close calls against Implementing Regulation (EU) 2025/2392 and keep a record.

Judgment call: Whether a product "has the function of a VPN" as its core purpose or merely includes VPN connectivity has no bright-line rule in the CRA; the implementing act controls the match.

What Class I changes: your conformity route Art. 32(1), Art. 32(2), Annex VIII

For a default-category product a manufacturer may self-assess under internal control (module A). For a Class I important product that choice narrows: internal control remains available only where you apply harmonised standards, common specifications, or a European cybersecurity certification scheme at assurance level at least "substantial", in full, to the relevant essential requirements.

Where you do not, or where no such standard yet exists, the product must go through EU-type examination plus conformity to type (modules B and C) or full quality assurance (module H), both involving a notified body. Plan for that lead time well before 11 December 2027.

Everything else is the ordinary manufacturer programme Art. 13, Art. 14, Annex I

Class I status changes the conformity route, not the substance. The essential cybersecurity requirements, vulnerability handling including a coordinated vulnerability disclosure policy, technical documentation, CE marking, and the reporting duties for actively exploited vulnerabilities and severe incidents apply to a VPN product as they do to any product in scope.

What you must do

  • Design, develop, and produce the product in line with the essential cybersecurity requirements. (Art. 13(1), Annex I Part I)
  • Handle vulnerabilities during the support period, including putting in place and enforcing a coordinated vulnerability disclosure policy. (Art. 13(8), Annex I Part II (5))
  • Draw up technical documentation and carry out the Class I conformity assessment: internal control only with harmonised standards, common specifications, or eligible certification applied in full, otherwise modules B and C or module H via a notified body. Then affix the CE marking. (Art. 13(12), Art. 32(2), Annex VIII)
  • Report actively exploited vulnerabilities and severe incidents once reporting duties start. (Art. 14)

The dates that decide your planning

11 September 2026
Reporting duties start. Actively exploited vulnerabilities and severe incidents must be reported via the single reporting platform: early warning within 24 hours, notification within 72 hours, then a final report (within 14 days after a corrective measure is available for vulnerabilities, within one month after the notification for severe incidents). (Art. 14, Art. 16, Art. 71(2))
11 December 2027
The full obligations apply: essential cybersecurity requirements, technical documentation, conformity assessment, and CE marking. (Art. 71(2))

Frequently asked

My app has a VPN feature but does other things too. Is it a VPN product?

Only if providing the VPN is its core functionality. Integrating VPN connectivity into a product that does something else does not, on its own, place the whole product in item 5, but a close call should be resolved against the implementing act and documented. (Art. 7(1), Art. 7(4))

Is a self-hosted VPN server in scope if we do not sell it?

Scope turns on making the product available on the EU market in the course of a commercial activity. Software you run purely for yourself is not placed on the market; a VPN product you supply to customers, paid or free of charge, is. (Art. 3(22), Art. 2(1))

Can I still self-assess as a Class I product?

Only where you apply harmonised standards, common specifications, or an eligible European cybersecurity certification scheme at assurance level at least "substantial" in full. Otherwise a notified body route applies (modules B and C, or module H). (Art. 32(2))

When does this start applying?

Reporting duties start 11 September 2026. The full obligations, including the Class I conformity route, apply from 11 December 2027. (Art. 71(2))

Check where your product lands, free

The Vexwatch Scope Checker walks the same cited decision tree in about three minutes: whether you are in scope, in which role, in which category, and which obligations hit on which date.

Check your scope, free See the Blueprint

This page is general information about Regulation (EU) 2024/2847, the EU Cyber Resilience Act. It is compliance tooling, not legal advice, and creates no client relationship. It may not reflect your specific circumstances or the most recent regulatory guidance. Verify conclusions against the regulation or qualified counsel before relying on them.