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Cyber Resilience Act

CRA Conformity Assessment: Self-Assessment vs. Third-Party Audit

Understanding the different conformity assessment paths under the CRA โ€” when you can self-assess and when you need a notified body.

Luca Berton6 min read

The CRA's conformity assessment requirements depend on your product's classification. Getting this right is critical โ€” using the wrong assessment path means your CE marking is invalid and your product cannot legally be sold in the EU.

Default Category โ€” Self-Assessment

For the majority of products (~90%), manufacturers can perform an internal conformity assessment. This means:

  • Evaluating the product against CRA essential requirements
  • Compiling a technical file documenting compliance
  • Drafting an EU Declaration of Conformity
  • Applying the CE marking

Important Class I โ€” Standards or Third-Party

For Class I products, you have two paths:

  • Option A: Apply harmonized standards (when available) and self-assess
  • Option B: Engage a notified body for third-party assessment

The harmonized standards being developed by ETSI are crucial here โ€” once published, they unlock the self-assessment path for Important Class I products.

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Important Class II โ€” Mandatory Third-Party

No self-assessment option. You must engage an accredited notified body to perform the conformity assessment. This includes type examination and production quality assurance.

Critical โ€” European Certification

The highest level. Products must obtain a European cybersecurity certificate under an EU certification scheme. These schemes are being developed under the Cybersecurity Act (Regulation 2019/881).

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Cost Implications

Third-party assessments typically cost โ‚ฌ20,000โ€“โ‚ฌ100,000+ depending on product complexity. Budget for this in your product development cycle โ€” it's no longer optional.

cra
conformity assessment
ce marking
notified body
compliance

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18+ years experience ยท Ex-Red Hat & Dell ยท Speaker at KubeCon EU 2026

Luca Berton

Written by

Luca Berton

CEO at Open Empower. 18+ years building enterprise infrastructure at JPMorgan Chase, Red Hat & Dell. Author of 9 technical books. Speaker at Red Hat Summit and KubeCon EU 2026. Instructor on Coursera, Pluralsight & Udemy.

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