Does the CRA only apply to devices connected to the Internet?
Betrifft der CRA nur Geräte, die mit dem Internet verbunden sind?
Answer:
No. This question is part of a common misunderstanding probably resulting out of the phrasing of “remote data processing solutions”. It is not relevant if a product is connected to the Internet or not. It is rather of relevance, if “the intended purpose or reasonably foreseeable use of which includes a direct or indirect logical or physical data connection to a device or network”. A logical connection can be e.g. “via network sockets, pipes, files, application programming interfaces or any other types of software interface” (Recital 9).
According to the definition, remote data processing should be such that “without it, the product with digital elements would not be able to perform one of its functions” (see Art. 3 No. 2 CRA). However, data processing is not a decisive factor for the applicability of the CRA but must also be taken into account in the event of applicability, such as the use of a cloud backend.
Most recent content update of this FAQ: September 2025
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