Official act · 1 December 2025

Check your product class against the new legal descriptions

Affected
New machines from 11 Dec 2027
Importers and distributors
Status
Official act
Date
Practical impact
Adds or clarifies a duty

What happened

Commission Implementing Regulation (EU) 2025/2392 of 28 November 2025 was published in the Official Journal on 1 December 2025. It gives the technical description of the product categories listed in Annex III (important products) and Annex IV (critical products) of the Cyber Resilience Act, as Articles 7(4) and 8 of the CRA require.

What it means for machine builders

This is the text that tells you whether a product you place on the market, or a component you build in, counts as important or critical. Routers, switches, firewalls, operating systems and microcontrollers with security functions are among the categories described. The class decides the conformity assessment route from 11 December 2027: self-assessment for the default category, a harmonised standard or a notified body for important class I and II, a notified body or certification for critical products. Compliance managers should map every connected product in the catalogue against these descriptions now.

Official source EUR-Lex, Commission Implementing Regulation (EU) 2025/2392

Published 16 October 2026 by Edge SDN. A summary, not legal advice. Always check the official text for your case.