Electronics

A CE mark after CRA is more than EMC and LVD.

Cybersecurity becomes a product property next to the older directives. The manufacturer needs a risk assessment, a bill of materials and a support period before the product is placed on the market.

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A CE mark after CRA does not close on EMC and LVD. Cybersecurity becomes a product property next to the older directives. The manufacturer needs a risk assessment, a bill of materials and a support period before the batch leaves the warehouse. From 11 December 2027 the EU declaration also carries Annex I.

One board under twenty SKUs is not automatically one file. Revision, firmware, market and the mark on the enclosure decide whether it is the same product. An Asian component without a supplier SBOM still has to be described: due diligence stays with you.

Market surveillance can ask for the file years after shipment. Crado AI ties the SKU to the revision, the SBOM and the CE checklist on-premise, before the carton leaves.

What is in scope in electronics

Consumer and industrial electronics

A device with digital elements placed under your mark. It does not have to be “smart” to be a PDE.

One board, many SKUs

A shared base does not cancel separate rows when firmware, market or marking differ. The catalogue shows what is shared and what is not.

Revision as version

A new board revision or new firmware is a file event. SBOM and risk follow the revision, not the trade name.

A declaration that grows in 2027

EMC and LVD stay. Annex I, conformity assessment and living evidence are added. Module A still needs the file.

Usual friction

One board, many SKUs and markets.
Asian components without a usable supplier SBOM.
An EU declaration that must also cover Annex I.

What Crado AI holds

SKUs tied to the technical file.
SBOM and gaps on a board revision.
A conformity checklist before shipment.

What usually hurts hardware

One board, twenty SKUs, three revisions in a quarter.
A component with no supplier SBOM - you still have to describe it.
An EU declaration that after 2027 also covers Annex I, not only EMC and LVD.

How CRA lands on hardware

SKU, revision and firmware tied to one technical file.
A board and software SBOM on that revision, with supplier gaps described, not hidden.
A risk assessment against Annex I before placing on the market, not after the first customer audit.
A support period with month and year on the packaging or in the purchase documents.
A CE checklist and declaration before WMS releases the batch.

What to close before shipment

01

SKU to file

Sales does not add a variant that is not in the catalogue. No row means no shipment.
02

Revision SBOM

What is on the board and in flash, not what was on the previous spin.
03

Suppliers without a file

A row: who was asked, what you did not get, how you closed diligence.
04

CE as a gate

Declaration and mark are not a slide. They are the product state before it leaves the warehouse.

Questions from electronics

Does CRA replace EMC or LVD?

No. It adds essential cybersecurity requirements and a CE mark in that regime. The older directives stay. After 2027 the file has to carry both if the product falls under them.

An EMS in Asia builds the board. Who is the manufacturer?

The CRA manufacturer is the person who places the product on the Union market under their name or trademark. A contract manufacturer does not lift the file if the mark is yours. An importer of a non-EU product picks up duties when they place it.

Is every revision a new CE?

A substantial modification is a new placing. A change that does not move the risk stays on the same row, but the SBOM and the revision trace still have to match what left the warehouse.

Why on-premise for hardware?

Board composition, supplier gaps and batches are data you do not want on a SaaS tenant. You install Crado AI at your site.

An SBOM under CRA is evidence, not a drawer PDF ->