CRA CE marking and declaration of conformity

A product with digital elements needs an EU declaration of conformity and the CE marking

Direct answer. In the consolidated text of Regulation (EU) 2024/2847, CELEX 02024R2847-20241120 (EN, 20.11.2024), Article 13(12) says that where compliance of the product with digital elements with the essential cybersecurity requirements in Part I of Annex I, and of the processes put in place by the manufacturer with the essential cybersecurity requirements in Part II of Annex I, has been demonstrated by the chosen conformity assessment procedure, manufacturers shall draw up the EU declaration of conformity in accordance with Article 28 and affix the CE marking in accordance with Article 30. Article 28 is titled “EU declaration of conformity.” Article 28(2) says the declaration shall have the model structure set out in Annex V and shall contain the elements specified in the relevant conformity assessment procedures set out in Annex VIII. The simplified declaration in Article 13(20) has the model structure set out in Annex VI. Article 30 is titled “Rules and conditions for affixing the CE marking.” Article 29 sends the general principles of that marking to Article 30 of Regulation (EC) No 765/2008. The procedures Article 32 names are listed below, in its words. When those articles apply is the CRA timeline. The support period on the product page is a different surface. This page is not legal advice.

CRALedger Duty Records (Shopify App Store · Write a review) tracks product roles, checklists and open record gaps, Article 14 deadlines, and draft reporting packs. The listing does not say the app draws up an EU declaration of conformity or affixes a CE marking. Manufacturer duties are Articles 13 and 14.

Related: EUDR Records Manager — DDS reference numbers on supplier lots.

Free check first: CRA role and scope self-check runs in your browser and sends nothing. Describe a product and your role and see which articles of Regulation (EU) 2024/2847 to read.

Checklist before you treat CE marking as done

Article 28 and Article 30

Article 28(1) says the EU declaration of conformity shall be drawn up by manufacturers in accordance with Article 13(12) and state that the fulfilment of the applicable essential cybersecurity requirements set out in Annex I has been demonstrated. Article 28(2) says it shall have the model structure set out in Annex V, shall contain the elements specified in the relevant conformity assessment procedures set out in Annex VIII, shall be updated as appropriate, and shall be made available in the languages required by the Member State in which the product is placed on the market or made available. The same article says the simplified EU declaration of conformity referred to in Article 13(20) shall have the model structure set out in Annex VI. Article 13(20) says manufacturers shall either provide a copy of the EU declaration of conformity or a simplified EU declaration of conformity with the product, and that where a simplified declaration is provided it shall contain the exact internet address at which the full declaration can be accessed. Article 28(4) says that by drawing up the declaration the manufacturer shall assume responsibility for the compliance of the product with digital elements.

Article 3 defines CE marking as a marking by which a manufacturer indicates that a product with digital elements and the processes put in place by the manufacturer are in conformity with the essential cybersecurity requirements set out in Annex I and other applicable Union harmonisation legislation providing for its affixing. Article 30(1) says the CE marking shall be affixed visibly, legibly and indelibly to the product with digital elements. Where that is not possible or not warranted on account of the nature of the product, it shall be affixed to the packaging and to the EU declaration of conformity referred to in Article 28 accompanying the product. For products in the form of software, the CE marking shall be affixed either to that declaration or on the website accompanying the software product. Article 30(3) says the CE marking shall be affixed before the product is placed on the market. Article 30(4) says the CE marking shall be followed by the identification number of the notified body where that body is involved in the conformity assessment procedure based on full quality assurance (based on module H) referred to in Article 32.

Conformity assessment procedures, as Article 32 names them

Article 32 is titled “Conformity assessment procedures for products with digital elements.” Article 32(1) says the manufacturer shall demonstrate conformity by using any of the following procedures:

Article 32(2) limits an important product with digital elements that falls under class I, in the case that paragraph describes, to either the EU-type examination procedure (based on module B) followed by conformity to EU-type based on internal production control (based on module C), or a conformity assessment based on full quality assurance (based on module H). Article 32(3) names, for an important product that falls under class II, the same module B followed by module C, full quality assurance (based on module H), or, where available and applicable, a European cybersecurity certification scheme pursuant to Article 27(9) at assurance level at least ‘substantial’ pursuant to Regulation (EU) 2019/881. Article 32(4) says critical products with digital elements listed in Annex IV shall demonstrate conformity by a European cybersecurity certification scheme in accordance with Article 8(1) or, where the conditions in Article 8(1) are not met, any of the procedures referred to in paragraph 3. Those are the procedure names that article uses.

What this page is not

Related pages

Not legal advice. Confirm Articles 13(12), 28, 29, 30, and 32, and Annexes V, VI, and VIII, on the live consolidated text before you treat a declaration or a CE marking as the one the regulation describes. The app tracks duty records you enter. It does not draw up a declaration or affix a marking.