Important products with digital elements as referred to in this Regulation should be understood as products which have the core functionality of a category of important products with digital elements that is set out in this Regulation. For example, this Regulation sets out categories of important products with digital elements which are defined by their core functionality as firewalls or intrusion detection or prevention systems in class II. As a result, firewalls and intrusion detection or prevention systems are subject to mandatory third-party conformity assessment. This is not the case for other products with digital elements not categorised as important products with digital elements which may integrate firewalls or intrusion detection or prevention systems. The Commission should adopt an implementing act to specify the technical description of the categories of important products with digital elements that fall under classes I and II as set out in this Regulation.
Recital 45
Regulation (EU) 2024/2847 — published 10 December 2024 · Last reviewed by Kunnus: March 2026
Quick Answer for Manufacturers
Recital 45 clarifies the 'important products' classification: the core functionality is decisive. Example: a smartphone app whose main purpose is password management falls under Class I — an app with password functionality as a side feature does not.
This quick answer + FAQ supplements the original legal text with practice-oriented interpretation. Only the original text is legally binding.
Common Manufacturer Questions
How do I determine the core functionality of a product?
Ask: what is the main purpose customers buy the product for? Not every feature qualifies the product as 'important.' A browser is primarily a browser, not a 'password manager,' even if it stores passwords.
What does this mean for multi-function products?
For devices with multiple functions, the main function decides. Hybrid products with equally weighted functions can fall into multiple categories — in which case the stricter classification applies.
Where can I find examples of the core-functionality logic?
Annex III lists concrete product categories. Recital 45 plus the official guidelines (forthcoming) clarify edge cases. ENISA will additionally issue industry-specific guidance.
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(1)This text is reproduced from Regulation (EU) 2024/2847 of the European Parliament and of the Council of 23 October 2024. It is provided for informational purposes only and does not constitute legal advice. Only the text published in the Official Journal of the European Union is legally binding. Original text on EUR-Lex