[throwaway294566]

No, the regulation explicitly includes components:

> For the purposes of this Regulation, the following definitions apply: (1) ‘product with digital elements’ means any software or hardware product and its remote data processing solutions, including software or hardware components to be placed on the market separately

https://ec.europa.eu/newsroom/dae/redirection/document/89543

[pyb]

Oh my, I need to update my understanding of CE markings if it's like this in this instance. This is going to be complete chaos.