Start from your role in the chain

If you place a product with digital elements — hardware or software — on the EU market, you are the manufacturer, and the full CRA obligations sit with you: the essential requirements of Annex I, vulnerability handling, a declared support period, the technical documentation and CE marking. This holds even if you manufacture outside the Union, because the CRA follows the product, not the location.

For an industrial manufacturer the game runs on two horizons: the reporting process to have ready by 11 September 2026, and substantive conformity to win by 11 December 2027. The operational content starts here.

Art. 13–14 · Annex I

If you place on the Union market a product made by a manufacturer established outside the EU, you are the importer. You do not design the product, but you cannot place a non-compliant one: first you must verify that the manufacturer has carried out the conformity assessment, that CE marking and technical documentation exist, and that the support period is declared. If a product presents a risk, you must inform the manufacturer and the market surveillance authorities.

Mind the boundary: if you place the product under your own name or trademark, or modify it substantially, you take on the manufacturer’s obligations.

Art. 19–20 · 22

If you make a product available on the market without being its manufacturer or importer, you are the distributor. Yours is a formal due-diligence duty: before making it available you check that the product bears the CE marking, that it comes with the required information and instructions, and that the manufacturer and importer have met their obligations. If you know — or should know — that a product is non-compliant, you cannot make it available until it is fixed.

The same boundary applies to you: if you place the product under your own trademark or modify it substantially, you answer as the manufacturer.

Art. 21–22