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Affixing the CE Marking to Your Software Product

You've done the hard yards: risk assessment, ensuring your app or game meets essential cybersecurity requirements, compiled technical documentation, and drawn up the EU Declaration of Conformity (DoC). The final step in this part of your Cyber Resilience Act (CRA) journey is affixing the CE marking.

What the CE Mark Signifies​

The CE marking is your visible declaration that your software product complies with the CRA and any other applicable EU laws requiring the mark. It’s the passport for your software to be made available on the EU market (Article 30, Paragraph 5, implies conformity with relevant legislation; Recital 36 states it indicates conformity with this Regulation).

How to Affix for Software​

For tangible products, the CE mark usually goes on the product itself or its packaging. But what about intangible software like your app, game, or a downloadable library? Article 30, Paragraph 1 of the CRA provides specific guidance:

  • Digital Placement: For products with digital elements which are in the form of software, the CE marking must be affixed either to the EU Declaration of Conformity or on the website accompanying the software product.
  • Accessibility: If placed on a website, the relevant section of the website must be easily and directly accessible to consumers.
  • Visibility and Legibility: The CE marking must be visible, legible, and indelible. Even if you use a small digital version, these principles apply.

When to Affix​

The CE marking must be affixed before your software product is placed on the market (Article 30, Paragraph 3). This means it's one of the last steps before you release or start selling your app or game in the EU.

General Principles​

Remember, the CE marking is subject to general principles laid out in Article 30 of Regulation (EC) No 765/2008, as referenced by CRA Article 29. This includes rules about its form and proportions.

Key Takeway​

For software, the CE marking is typically applied digitally—on the DoC or an accompanying website. It must be done before market placement and signifies your product's compliance with the CRA.