Product Classification

Overview

Every product with digital elements must be classified into a CRA risk category under the Cyber Resilience Act (CRA). The classification determines the required conformity assessment procedure. The CRA distinguishes four categories: Standard, Class I (Important), Class II (Important), and Critical.

Classification Decision Tree

The following decision tree outlines the systematic approach to product classification:

Is the product listed in Annex IV?
├── Yes → CRITICAL (EUCC required)
└── No
    └── Is the product listed in Annex III?
        ├── Yes → Which class?
        │   ├── Class II → CLASS II (Module B+C or H)
        │   └── Class I → CLASS I (Module A* or B+C)
        └── No → STANDARD (Module A)

* Module A only where harmonised standards are applied in full

Product Categories

Category: Standard (Default)

Conformity assessment: Internal control (Module A) -- Self-assessment

The majority of products fall into this category. The manufacturer carries out the conformity assessment themselves.

Typical Products:

• Standard web applications
• Internal tools and utilities
• Non-critical container images
• Simple IoT sensors

Class I (Annex III)

Conformity assessment: Internal control (Module A) with application of harmonised standards OR EU type examination (Module B+C)

Examples from Annex III:

• Identity management systems and software for privileged access
• Browsers (standalone)
• Password managers
• Software for searching, removing, and quarantining malware
• VPN products
• Network management systems
• SIEM systems
• Boot managers
• Firewalls, IDS/IPS (non-industrial)
• Routers, modems (for internet access)
• Microcontrollers with security-relevant functions
• Operating systems (not for server/desktop Class II)

Class II (Annex III)

Conformity assessment: EU type examination (Module B+C) OR Comprehensive quality assurance (Module H)

Examples from Annex III:

• Hypervisors and container runtime environments
• Firewalls and IDS/IPS for industrial use
• Tamper-resistant microcontrollers/microprocessors
• Operating systems for servers, desktops, mobile
• Public key infrastructure and certificate issuers
• Industrial automation and control systems (IACS)
• Industrial IoT devices (not subject to other sectoral regulation)

Category: Critical (Annex IV)

Conformity assessment: European cybersecurity certificate (EUCC) at assurance level "substantial" or higher

Examples from Annex IV:

• Hardware security modules (HSM)
• Smart cards and similar devices (incl. secure elements)
• Smart card readers
• Sensors and actuators for robots and machine controllers
• Smart meter gateways

Conformity Assessment by Category

Category	Module A (Self)	Module B+C (Type)	Module H (Quality)	EUCC
Standard	✅	-	-	-
Class I	✅*	✅	-	-
Class II	-	✅	✅	-
Critical	-	-	-	✅

* Only when applying harmonised standards or when conforming with EU cybersecurity certification

Relevant Product Types for BAUER GROUP

Review against Annex III (Important Products)

Annex III Category	Applicable to BAUER GROUP?	Rationale
Identity Management Systems	To be reviewed	If IAM solutions are offered
Password Managers	To be reviewed	If credential management is offered
VPN Products	To be reviewed	If VPN solutions are offered
Network Management Systems	To be reviewed	If network tools are offered
Firewalls, IDS/IPS	To be reviewed	If security products are offered
Routers, Modems	To be reviewed	If network hardware with firmware
Microcontrollers (security-relevant)	Likely yes	ESP32/STM32 firmware with security-relevant functions
Operating Systems	To be reviewed	If OS-level products
Container Runtime	No (as a rule)	We use containers but do not offer a runtime
Hypervisor	No (as a rule)	We use hypervisors but do not offer one
Industrial IoT Devices	Likely yes	If IoT devices for industrial use

Review against Annex IV (Critical Products)

Annex IV Category	Applicable to BAUER GROUP?	Rationale
Hardware Security Modules (HSM)	No (as a rule)	We use HSMs but do not manufacture them
Smartcards / Secure Elements	No (as a rule)
Smart Meter Gateways	To be reviewed	If energy products

Typical Classification for BAUER GROUP Products

Product Type	Expected Class	Assessment Procedure
Standard web application	Standard	Module A
REST API	Standard	Module A
Container image (microservice)	Standard	Module A
NPM/NuGet Library	Standard	Module A
ESP32 IoT sensor (non-safety-critical)	Standard	Module A
ESP32/STM32 industrial controller	Class I	Module A* or B+C
Firmware with authentication function	Class I	Module A* or B+C
Network router with firmware	Class I	Module A* or B+C

Classification Process

The following process must be carried out for each product:

1. Functional Review

Verify whether the product fulfils one of the functions listed in Annex III or IV. Systematically compare against all categories.

2. Intended Purpose

Consider the intended purpose:

• Is the product used in critical infrastructure?
• Does it process sensitive/personal data?
• Does it have network functionality?
• Could a compromise cause physical damage?

3. Document the Classification

Use the template Risk Assessment to document the classification decision.

RECOMMENDATION

When in doubt, choose the higher category. A conservative classification is regulatorily safer than one that is too low.

Documentation of the Classification

For each product, the classification is documented in the Product Description:

1. Review against Annex III and IV -- Systematic comparison against all categories
2. Rationale -- Why this classification applies (with reference to the Annex)
3. Conformity Assessment procedure -- Which module is applied
4. Date -- When the classification was carried out
5. Responsible person -- Who carried out the classification