Does a product which includes an open source component belonging to the category of important products (Annex III) inherit that category?
The CRA states in Article 7(1) that “the integration of a product with digital elements which has the core functionality of a product category set out in Annex III shall not in itself render the product in which it is integrated subject to the conformity assessment procedures referred to in Article 32(2) and (3).” Therefore, products do not automatically inherit the classification of an integrated component. Instead, it comes down to the intended core functionality.
Example: if an operating system, which is a type of product classified as important, is integrated into a product which provides functionality that is not classified as important (e.g., an alarm clock), then this particular product (the alarm clock) is not classified as important product. If the core functionality of the product itself however is an operating system and can be used as such, it qualifies as an important product.