Question 1

My device uses a microcontroller with security features. Is my device Class I?

Accepted Answer

Not because of that alone. Integrating a Class I component does not make the device Class I; its own core functionality decides (CRA Art. 7(1); Guidance ¶141, Example 58).

Question 2

Does the companion app need its own CE marking?

Accepted Answer

If the app is needed to operate, configure or use the device, the Commission treats device and app as one product (Guidance ¶25). For software products, the CE marking goes on the declaration or the accompanying website (CRA Art. 30(1)).

Question 3

Can I self-assess a Class I smart lock?

Accepted Answer

Only if you apply a harmonised standard, common specification or certification scheme in full; otherwise a notified body is involved (CRA Art. 32(2)). No CRA harmonised standard was cited as of 2026-10-09 (Commission).

Question 4

Do units already sold need CE marking under the CRA?

Accepted Answer

No. Products placed on the market before 11 December 2027 are covered only by Article 14 reporting, unless substantially modified from that date (CRA Art. 69(2)–(3)).

Question 5

Who signs the declaration of conformity?

Accepted Answer

The manufacturer draws it up and, by doing so, takes responsibility for the product's compliance (CRA Art. 13(12), 28(1), (4)). Annex V ends with "signed for and on behalf of", with place and date of issue and the signatory's name and function (CRA Annex V).