Answer the questions and see the reasoning.
Match the routing function
The Class I category covers routers, modems intended for connection to the internet, and switches under the implementing technical descriptions. A routing product directs data packets between networks; check its actual functions against the full description.
Do not classify only by the product name. A multipurpose appliance marketed as a “gateway” may need a router, firewall or other category assessment depending on its core functionality.
A router with a firewall is not automatically Class II
The implementing act specifically addresses integrated functions. A router incorporating ancillary firewall functions can still have routing as its core functionality. The presence of that component alone does not resolve the classification.
If protecting traffic through firewall or intrusion-prevention functionality is itself the core product purpose, the Class II description may be relevant. Preserve the feature specification and the reasoning for distinguishing central from ancillary functions.
Choose the assessment route with evidence
For Class I, check whether the relevant harmonised standards, common specifications or qualifying certification satisfy Article 32(2). If the conditions do not hold, a B+C or H assessment is needed for the relevant requirements. A certificate to an unrelated standard is not enough.
The manufacturer must also handle vulnerabilities, support secure updates and document support information. An importer or distributor of another brand has distinct verification duties and may take on manufacturer duties if it rebrands or substantially modifies the product.
Dates and next actions
Article 14 reporting for manufacturers applies from 11 September 2026, including to older in-scope products. Most requirements apply from 11 December 2027, subject to the rules for products already placed on the market and subsequent substantial modifications.
If you are the manufacturer of an in-scope product, establish the product risk assessment, support-period decision, vulnerability handling and technical documentation. Select the applicable conformity route before making a compliance claim. A reseller should use the importer and distributor assessment for its distinct duties.
Frequently asked questions
Are all routers Critical products?
No. The router category is Important Class I. Critical categories are separately defined in Annex IV.
Does including firewall rules always make a router Class II?
No. Examine the core functionality of the whole product and the implementing technical descriptions. An ambiguous multifunction product needs further assessment.