CE Marking for Digital Products Under the CRA: What You Need to Know

CE marking is the passport for products sold in the EU single market. The CRA extends this requirement to all products with digital elements, including standalone software.

What CE Marking Means Under the CRA

By affixing the CE mark, the manufacturer declares that the product meets all applicable essential requirements of the CRA (and any other applicable EU harmonization legislation). It's a legal statement, not a quality badge.

Steps to CE Marking

1. Identify applicable requirements — CRA essential requirements + any sector-specific regulations
2. Perform conformity assessment — Self-assessment or third-party, depending on product classification
3. Compile technical documentation — Risk assessment, design decisions, test results, SBOM
4. Draft EU Declaration of Conformity — Formal statement listing the product, manufacturer, and applicable requirements
5. Affix CE marking — On the product, packaging, or accompanying document (for software: in digital form, e.g., splash screen or about page)

For Software Products

Since software doesn't have a physical label, the CE marking should be displayed digitally — in the product's documentation, download page, or user interface. The EU Declaration of Conformity must be accessible to users.