Jurisdiction(s):
European Union

EU Cyber Resilience Act: material, personal and territorial scope; product classification; exemptions; and obligations of manufacturers, importers, distributors and open‑source stewards when placing products on the EU market

Published by a LexisNexis EU Law expert

Practice notes

This Practice Note outlines the material, personal and territorial reach and application of Regulation (EU) 2024/2847, the EU Cyber Resilience Act (CRA). It further sets out how products are categorised under the CRA, including non‑critical, important and critical products. For further background on the CRA and the key obligations placed on economic operators, see the following Practice Notes:

The EU Cyber Resilience Act—overview and regulatory framework
The EU Cyber Resilience Act—obligations, compliance and enforcement

The CRA is the first EU measure of its kind, imposing mandatory cyber security standards for ‘products with digital elements’ across the Union. Items failing to satisfy these requirements will be barred from sale on the EU market from December 2027 onwards. Meeting the CRA will therefore be vital for market entry into the EU for both hardware and software. Manufacturers, importers and distributors of such products will shoulder extensive cyber security duties and may face significant financial penalties if they fail to comply. The CRA was published in the Official Journal of the EU (OJEU) on 20 November 2024, and subsequently took effect on 10 December 2024, and will apply in full from 11 December 2027 across the EU.

Material scope

The CRA’s material scope...

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Dr Henrik Hanssen

Hogan Lovells International LLP

Henrik Hanssen is an expert for data, data privacy, AI, IT, cybersecurity, e-commerce and digital media law. He advises national and international companies on regulatory challenges in the digital sector and represents his clients in contract negotiations, proceedings with regulators and in court proceedings. He brings extensive experience in the creation of practicable solutions to challenges under regulations such as the GDPR, the EU Data Act and EU AI Act, whether it is the evaluation of new products, coordinating regulatory compliance implementation projects, the drafting of policies, notices, agreements and other legal texts, in-house trainings or contentious matters. Due to several secondments, including with a leading global cloud computing provider, Henrik has special expertise in the tech industry and the field of cloud computing, and is familiar with the work and view of an in-house counsel. Prior to his career as attorney, Henrik studied law in Kiel with a...

Web page updated on 21/05/2026

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