What determines if a product with digital elements is an important or critical product?
In accordance with Articles 7(1) and 8(1), a manufacturer should look at the core functionality of its product with digital elements to determine whether that product is an important or critical product with digital elements and is therefore subject to the corresponding conformity assessment procedures.
The technical descriptions of the categories of important and critical products with digital elements are laid down in Commission Implementing Regulation (EU) 2025/2392 of 28 November 2025 on the technical description of the categories of important and critical products with digital elements.
Disclaimer
Disclaimer: This document is prepared by the Commission services and should not be considered as representative of the European Commission’s official position. The replies to the FAQs do not extend in any way the rights and obligations deriving from applicable legislation nor introduce any additional requirement. The expressed views are not authoritative and cannot prejudge any future actions the European Commission may take, including potential positions before the Court of Justice of the European Union, which is competent to authoritatively interpret Union law.