Product with digital elements (PDE)
Any software or hardware product, and its remote data processing solutions, whose intended or reasonably foreseeable use includes a direct or indirect logical or physical data connection to a device or network. The CRA applies to PDEs unless a sectoral carve-out applies (medical devices, motor vehicles, aviation, marine, etc.).
Source citations
Regulation text
Article 3(1) of Regulation (EU) 2024/2847 defines a product with digital elements as:
"any software or hardware product and its remote data processing solutions, including software or hardware components to be placed on the market separately".
Key points
- Both hardware and software products can be PDEs
- The data-connection requirement is intentionally broad — "logical or physical, direct or indirect"
- Standalone software with no network connectivity is still a PDE if it has a "logical" connection (e.g. USB port, local API)
- See the RDPS test to determine whether a remote service is part of your PDE