CRA Smart Plug China Seller Amazon Germany

Key numbers

Default

WiFi smart plug without security functionality. Not in Annex III. Module A self-assessment — no notified body.

Module A

Internal control procedure. Art. 32.1(a). You assess, you document, you declare.

€149

Per product model. One smart plug SKU = one licence = 8 documents.

How CRACheck works

You enter your product data. CRACheck structures the documentation per Article 31 + Annex VII.

Confirm Default classification

Your WiFi smart plug is not in Annex III (no security functionality). Default product. Module A applies.

Gather product data

WiFi chip model, firmware version, Tuya integration details, OTA update mechanism, default credential policy, intended support period.

Generate dossier

Enter data in CRACheck. 15-25 minutes. Download 8 PDFs in ZIP.

Store for Amazon compliance

Save the ZIP in your Seller Central compliance folder. Upload when Amazon opens the CRA dashboard.

Repeat for other smart plug variants

If you sell a 2-pack, a mini version and an outdoor version with different firmware, each model needs its own dossier.

Common mistakes

❌

ART. 2.1

"A smart plug is too simple for CRA — it just switches a relay"

Article 2.1 applies to all products with digital elements that have a direct or indirect data connection. Your smart plug connects via WiFi to an app. Complexity is not the threshold — connectivity is.

❌

ANNEX I, PART I

"The plug runs on Tuya firmware — Tuya handles security"

Article 13.5 requires manufacturers to exercise due diligence when integrating third-party components. If your plug uses Tuya firmware, you must document that the Tuya component does not compromise your product's cybersecurity.

❌

ANNEX I, PART I, 1(d)

"Users set up the plug with our app — they handle security"

Annex I Part I point 1(d) requires products to be delivered with secure by default configuration. If your plug ships with an open WiFi access point for setup, or requires a default password common across all units, it may not meet this requirement.

What the ZIP contains

8 PDF documents generated from your data. Each cites the specific article of Regulation (EU) 2024/2847 it complies with.

Product Classifier

Confirms Default classification. Documents that Annex III does not apply. Defines Module A.

Technical Documentation

Art. 31 + Annex VII. Covers WiFi module, Tuya integration, OTA update, relay control interface, data flow.

Risk Assessment

Art. 13.2-13.3. Risk analysis: unauthorized access, firmware tampering, network exposure.

User Information

Annex II. Secure setup, WiFi password requirements, support period, vulnerability reporting.

Declaration of Conformity

Art. 28 + Annex V. You sign this as manufacturer under Module A.

CVD Policy

Vulnerability disclosure channel for your smart plug.

Notification Template

Art. 14. Pre-structured for the 24h/72h/14d timeline.

Obligations Calendar

Key CRA dates for your smart plug lifecycle.

See before you buy — Download sample dossier (PDF, fictional company) — Real structure, real articles, real format. Fictional data.

Generated from your data, in your browser. No data leaves your device.

What you pay

🧾 GERMAN COMPLIANCE AGENCY FOR SMART HOME

€2,000–€4,000

Per product. 3-6 weeks. Overpaying for a Default product.

✓ CRACHECK

€149

8 documents. 15 min. Right-sized for a Default product. Pack 10: €99/product.

Two layers

● LAYER 1

What CRACheck does

Generates the Annex VII documentation for your WiFi smart plug. Default product, Module A self-assessment. 8 structured documents.

∅ LAYER 2

What CRACheck does NOT do

CRACheck does not test your plug's WiFi security, scan the Tuya firmware for vulnerabilities or certify the product. For Default products, no third-party certification is required — but the product itself must meet Annex I requirements.

We generate documentation. You ensure the product is secure.

Enforcement regime

Article 64 of Regulation (EU) 2024/2847.

🔴

Non-compliance with Annex I + Art. 13/14 (Art. 64(2))

€15,000,000 / 2.5%

Art. 64.2.

🟠

Non-compliance with Art. 31, Art. 28, Art. 32 (Art. 64(3))

€10,000,000 / 2%

Art. 64.3.

🟡

Incorrect or misleading information (Art. 64(4))

€5,000,000 / 1%

Art. 64.4.

Alternatives

Criterion	German compliance agency	Ask Tuya for compliance documentation	Wait for Amazon to enforce	CRACheck
Cost	€2,000–€4,000	Variable	€0 now	€149
Result	3-6 weeks. Expensive for a Default product.	Tuya provides platform-level docs. Product-level Annex VII is your obligation.	48h scramble when it happens. GPSR pattern.	8 docs. 15 min. Default product, right-sized solution.

You sell multiple smart plug models on Amazon Europe?

Mini plug, outdoor plug, power strip with WiFi — each model with different firmware or hardware needs its own dossier. Volume pricing: €99/product (10-pack), €79/product (30-pack).

Request Volume Pricing

Response within one business day.

What CRACheck guarantees and what it does not

CRACheck generates a structured document according to Article 31 and Annex VII of Regulation (EU) 2024/2847 from the information you provide. The accuracy, completeness and truthfulness of that information is your responsibility as the manufacturer.

We guarantee that the document structure follows Article 31 and Annex VII of Regulation (EU) 2024/2847 and that the legal references cited are correct. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case or by a commercial buyer in a procurement process.

CRACheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions

Is a WiFi smart plug really in scope of the CRA?

Yes. Article 2.1 covers products with digital elements that have a data connection. A WiFi smart plug has a WiFi data connection. It is in scope.

Is a Tuya-based plug Default or Class I?

A smart plug that switches a relay and has no security functionality is not listed in Annex III. It is a Default product. If the plug includes a camera, a motion sensor marketed for security, or functions as a home alarm component, it could fall under Annex III point 17.

Do I need separate documentation for Amazon.de, Amazon.fr and Amazon.es?

No. The CRA documentation is for the product, not for the marketplace. One dossier per product model covers all EU marketplaces.

What support period should I declare for a smart plug?

Article 13.8 requires a support period reflecting expected time of use. For a smart plug, consumers expect 3-5 years. Recital 59 references 5 years as a default.

Can I generate the dossier in Chinese?

CRACheck generates documents in English. Article 31.4 requires documentation in a language acceptable to the relevant authorities. English is accepted across the EU.

Is this a subscription?

No. One-time payment. 30 days editing, 10 regenerations. PDF yours permanently.

Can I request a refund?

Pursuant to Art. 16(m) of Directive (EU) 2011/83, licence activation constitutes express consent. Refunds only for reproducible technical failures.

What if the regulation changes?

Regenerate at no additional cost during licence validity.

Official legal sources

Regulation (EU) 2024/2847 — Cyber Resilience Act — full text

⚠️ Important notice: CRACheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document under Article 31 and Annex VII of Regulation (EU) 2024/2847 is generated from your input data. You are responsible for the accuracy of the data you provide. CRACheck does not replace a qualified professional assessment.