Remote data processing solution (RDPS)
A remote service that is necessary for a product with digital elements to perform any of its functions. An RDPS is part of the PDE and therefore subject to the same CRA obligations as the product itself. The three-part test (at-a-distance, functional dependency, manufacturer responsibility) determines whether a remote service qualifies.
Source citations
Three-part RDPS test
The Commission's March 2026 draft guidance (§ 8) sets out three conditions that must all be satisfied for a remote service to be an RDPS:
- At a distance — the data processing takes place remotely (not on the device)
- Functional dependency — the product cannot perform at least one of its intended functions without the remote service
- Manufacturer responsibility — the manufacturer controls or is responsible for the remote service (third-party SaaS used as a component is not an RDPS)
If all three conditions are met, the remote service is an RDPS and must comply with the same Annex I requirements as the physical product.