No, the regulation explicitly includes components: > For the purposes of this Regulation, the following definitions apply: (1) ‘product with digital elements’

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