CRA Implementing Regulation

(4) The fact that a product with digital elements performs functions other than or additional to those detailed in the technical descriptions set out in this Regulation does not in itself mean that the product with digital elements does not have the core functionality of a product category set out in Annexes III and IV to Cyber Resilience Act (CRA). For example, products with digital elements that have the core functionality of ‘operating systems’ often include software that performs ancillary functions not included in the technical description of that product category, such as calculators or simple graphics editors. Products with digital elements often also incorporate components that have the functionality of another important or critical product with digital elements, such as an operating system integrating browser functionality, or a router integrating firewall functionality. This, however, does not in itself mean that such products with digital elements do not have the core functionality of ‘operating systems’ or ‘routers, modems intended for the connection to the internet, and switches’, respectively.