CE marking communicates the manufacturer's conformity conclusion; it is not the conformity assessment itself. The marking must be in place before market placement. Article 30 contains specific rules for physical products, software, small markings and Module H notified-body identification numbers.
CE Marking Comes After Successful Conformity Assessment
Article 13 requires manufacturers to complete the applicable conformity assessment and, where compliance has been demonstrated, draw up the EU declaration of conformity and affix the CE marking. The CE mark therefore communicates a completed conformity conclusion. It does not replace the cybersecurity risk assessment, technical documentation, testing or Article 32 procedure.
- Assess conformity first.
- Draw up EU declaration.
- Affix CE marking.
- Then place product on market.
Article 29 Applies the General EU CE-Marking Principles
Article 29 states that CRA CE marking is subject to the general principles in Article 30 of Regulation (EC) No 765/2008. The CRA then adds product-specific rules and conditions in Article 30 of Regulation (EU) 2024/2847. Manufacturers should therefore treat the CRA rules as part of the wider EU CE-marking framework rather than as an unrelated cybersecurity logo system.
- CE marking is part of the EU harmonisation framework.
- Article 29 incorporates the general principles.
- CRA Article 30 adds CRA-specific placement rules.
The Mark Must Normally Be on the Product
Article 30 requires the CE marking to be affixed visibly, legibly and indelibly to the product with digital elements. Physical products should therefore use the product itself as the default marking location where the nature of the product makes that possible and warranted.
- Visible.
- Legible.
- Indelible.
- Normally on the product.
Packaging and the Declaration Are Used When Product Marking Is Not Suitable
Where affixing the CE marking to the product is not possible or is not warranted because of the nature of the product with digital elements, Article 30 requires it to be affixed to the packaging and to the EU declaration of conformity accompanying the product. This is a specific alternative-placement rule rather than a general option to omit product marking for convenience.
- Assess whether product marking is possible.
- Assess whether product marking is warranted.
- If not, use packaging.
- Also use the accompanying EU declaration.
Software Has a Specific CE-Marking Rule
For products with digital elements in the form of software, Article 30 allows the CE marking to be affixed either to the EU declaration of conformity or on the website accompanying the software product. Software manufacturers therefore do not need to invent a physical label for a purely digital product when the Regulation provides these digital placement options.
- Option 1: EU declaration of conformity.
- Option 2: website accompanying the software product.
- Use the CRA software-specific placement rule.
The Software Website Section Must Be Easily and Directly Accessible
Where the software manufacturer uses the accompanying website for CE marking, Article 30 requires the relevant section of that website to be easily and directly accessible to consumers. The marking should therefore not be buried behind unrelated support pages, obscure navigation or an inaccessible account workflow.
- Easily accessible.
- Directly accessible.
- Accessible to consumers.
- Use a stable product-facing location.
The CE Mark Can Be Smaller Than 5 mm in Some Cases
Article 30 provides that, because of the nature of the product with digital elements, the height of the CE marking affixed to the product may be lower than 5 mm, provided that it remains visible and legible. The rule is therefore not a general permission to shrink the mark arbitrarily; the product's nature must justify the smaller marking and readability must remain.
- Below 5 mm can be possible.
- Product nature must justify it.
- Mark must remain visible.
- Mark must remain legible.
Affix the CE Mark Before Market Placement
Article 30 requires the CE marking to be affixed before the product with digital elements is placed on the market. Manufacturers should therefore include CE-marking verification in the final release or market-placement checklist rather than treating the mark as post-launch administrative work.
- Complete conformity assessment.
- Complete declaration.
- Affix CE mark.
- Then place product on market.
Article 30 Allows Future Cybersecurity Pictograms or Marks
Article 30 states that the CE marking may be followed by a pictogram or another mark indicating a special cybersecurity risk or use set out in implementing acts referred to in Article 30(6). Manufacturers should distinguish any such future CRA implementing-act marking from marks created voluntarily for marketing purposes.
- Possible CRA cybersecurity pictogram.
- Requires the relevant implementing-act basis.
- Separate regulatory markings from voluntary marketing marks.
Module H Adds the Notified Body Identification Number
Article 30(4) requires the CE marking to be followed by the identification number of the notified body where that body is involved in the full quality assurance procedure based on Module H. The number is affixed by the notified body itself or, under its instructions, by the manufacturer or the manufacturer's authorised representative.
- Applies to Module H.
- Use notified-body identification number.
- Body can affix it.
- Manufacturer or representative can affix it under body instructions.
Do Not Automatically Apply the Module H Number Rule to B Plus C
Module B also involves a notified body, but Article 30(4) specifically identifies the full quality assurance procedure based on Module H for the CE-marking identification-number rule. Manufacturers should therefore not assume that the notified body's number from a Module B EU-type examination automatically follows the CE mark during the Module C production-conformity stage.
- Module B uses a notified body.
- Module C follows Module B.
- Article 30(4) expressly names Module H.
- Do not transfer the Module H marking rule automatically.
One CE Mark Can Also Represent Other Applicable EU Harmonisation Requirements
Article 30 provides that where the product is subject to other Union harmonisation legislation that also requires CE marking, the CE marking indicates that the product also fulfils those other applicable Union harmonisation requirements. Manufacturers should therefore coordinate CRA conformity with other CE-marking regimes rather than treating each regime as requiring an unrelated CE symbol.
- Identify other applicable EU harmonisation legislation.
- Coordinate conformity evidence.
- Use CE marking within the combined applicable framework.
CE Marking Does Not Replace Product Traceability
The CE mark indicates conformity, but it does not identify which product version, model or release was assessed. Manufacturers still need the product identifiers, technical documentation, declaration and version evidence required by the CRA. A CE-marked software download should therefore remain traceable to the conformity evidence supporting that release.
- Maintain product identifiers.
- Maintain release identifiers.
- Maintain declaration.
- Maintain technical documentation.
Update Marking Controls When Product Delivery Changes
A change from packaged hardware to digital delivery, a new software distribution channel or a new product configuration can change how Article 30 marking requirements are implemented. Release and compliance teams should review CE-marking placement whenever the product form or delivery model changes, while preserving the underlying conformity evidence.
- Review new delivery channels.
- Review digital distribution.
- Review packaging changes.
- Review software website location.
- Preserve conformity evidence.
A Practical CRA CE-Marking Release Check
Before market placement, verify that the applicable conformity assessment is complete, the EU declaration of conformity is current, the correct product or software release is covered, the CE mark appears in an Article 30-compliant location, visibility and legibility requirements are satisfied, the Module H identification number is present where required and any software website location is easily and directly accessible to consumers.
- Conformity assessment complete.
- Declaration current.
- Correct product version.
- Correct marking location.
- Visible and legible.
- Indelible where product marking applies.
- Module H number where required.
- Software website accessible where used.
Official sources
Read the full legal text and Commission material for precise wording, qualifications and updates.