CRA harmonised standards — citation and assessment checks

A work programme, draft standard or published EN title is different from an OJ citation conferring a particular presumption of conformity. Check the act-specific citation, date, edition, scope and restrictions. The current application does not automatically ingest the STAN4CR programme, all OJ notices or clause-level standard deltas.

Conformity assessment A, B+C and H

Annex VIII offers internal control (A), EU-type examination plus conformity to type (B+C), and full quality assurance (H). Standard products may use A. Important Class I A depends on Article 32(2) full coverage through applicable harmonised standards, common specifications or qualifying certification; otherwise B+C or H. Class II uses B+C or H under Article 32(3). Article 32(5) allows qualifying important free/open-source software with public technical documentation to use A. Critical products require assessment of Article 8 certification conditions; absent the mandated suitable scheme conditions, Article 32(4) provides B+C or H. Classify the main product function against Annexes III/IV and implementing technical descriptions 2025/2392, not a component name alone.

Cybersecurity and vulnerability handling

Part I point 1 establishes risk-based appropriate cybersecurity. Point 2(a)-(m) addresses known exploitable vulnerabilities, secure defaults, updates, access control, confidentiality, integrity, data minimisation, availability, network effects, attack surface, exploitation mitigation, logging, and secure permanent erasure/easy secure transfer of data. Apply requirements on the statutory risk-based conditions. Part II covers vulnerability identification/documentation including SBOM, remediation, testing, disclosure, contact, secure distribution and timely security updates. A proposed control or file count is not evidence that the control was tested.

Conformity assessment

For Article 3(1) requirements, Article 17(2) permits A, B+C or H. For Article 3(2)/(3), Article 17(3) permits A, B+C or H where applicable OJ-listed harmonised standards are fully applied; absent/partially applied standards, Article 17(4) requires B+C or H. Check exact editions, scope and OJ restrictions. EN 18031 citations under 2025/138 carry limitations; neither EN 18031 nor ETSI EN 303 645 automatically gives CRA presumption of conformity.

Evidence to keep with the product

Record the intended purpose, responsible economic operator, target market, first placing date and exact hardware/firmware configuration. For each applicable requirement, link the actual test or assessment record, dated standard/specification, scope and reviewer decision. Proposed controls and supplier marketing statements are not evidence that the final configuration has passed an assessment.

Separate an open question from a completed assessment. A report outside the laboratory's relevant scope, a different firmware build or an unverified exemption needs a reasoned decision before it supports a declaration. Keep original evidence and the issued declaration alongside any AI-assisted working draft.

Using Cenitia for this work

Cenitia assists with a limited regulatory catalogue and draft documents. The manufacturer must confirm applicability, actual applied specifications and completed assessment procedures. AI scores are quality signals, not a probability of conformity. Source monitoring raises a review prompt when validated source text changes; it does not automatically verify amendments, update the corpus or monitor every national rule and OJ standard edition. Public QR verification records issuance, not product certification.

Review status

This guide was substantively corrected by Cenitia on 2 October 2026 using the primary references below. It is an editorial summary, not an authoritative legal quotation or an independently signed expert opinion. Product-specific and licensed-standard questions remain subject to a real technical review.

Primary references

• Primary source 1
• Primary source 2