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Defined term

Product with digital elements

The gateway definition: hardware or software plus the remote processing it depends on.

LAW Defined in Article 3 (Art. 3(1)). The verbatim definition is in the official text of Article 3; only the Official Journal is authentic.

BINDING Source: Regulation (EU) 2024/2847 (Cyber Resilience Act) · publisher European Union · captured 2026-09-16 · snapshot sha256:27b7c6c64c773001… · CELEX 32024R2847

The whole Regulation hangs on this term: a product with digital elements is a software or hardware product and its remote data processing solutions F-005.

The second half is the part people miss. Where a product depends on your own remote data processing — a backend or API without which it cannot perform one of its functions — that processing is part of the product F-107, because remote data processing means processing designed and developed by the manufacturer, or under its responsibility, and needed for one of the product's functions F-006.

What this means in practice

An app that is a shell around your API is one product, app plus API F-107. A cloud service that is not part of a product sits outside the Regulation and may fall under NIS2 instead F-008. The line is drawn by design dependence, not by deployment architecture.

Verified facts this page relies on

Facts are maintained and human-verified in the CEMarque Facts Table (v2026.09.4, verified 2026-09-10).

Editorial review: Claude (AI reviewer, delegated by the editor), 2026-10-08. Methodology and correction process: how this site works.

Related in the reference

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