Questions and answers

Because the CRA sits within the New Legislative Framework product-law architecture and uses the same core concepts that the Blue Guide explains, including placing on the market, making available on the market, CE marking, technical documentation, declarations of conformity, notified bodies, and market surveillance.

The Commission's CRA FAQ repeatedly relies on the Blue Guide when explaining those concepts, and the Commission guidance adopted in July 2026 expressly describes the CRA as being built on the NLF.

Use the date and facts for the individual product, not the model's original release date. The CRA generally applies from 11 December 2027. Products placed on the market before that date are generally subject to the CRA only if they undergo a substantial modification from that date, while Article 14 reporting applies to in-scope products placed earlier as well.

Article 14 reporting starts on 11 September 2026, and the conformity-assessment-body provisions in Chapter IV have applied since 11 June 2026. A placement record should therefore identify the individual unit or software product, when manufacture was complete, the first supply transaction, the applicable product version, and whether a later change is a substantial modification.

It is the first making available of an individual product on the Union market.

That is the decisive timing point for CRA compliance, because the applicable requirements are assessed when the individual product is first placed on the market.

The required compliance work must already be complete at that point.

The Blue Guide says that, by the time of placing on the market, the manufacturer must have completed the design work against the applicable requirements, the relevant risk and conformity assessment, the declaration of conformity, the marking steps and the technical file. The CRA aligns with that logic by requiring the technical documentation to be drawn up before placement on the market and the cybersecurity risk assessment to be included in it.

The role follows the supply-chain function, not the job title on an org chart.

Under the CRA, the manufacturer is the actor that develops, manufactures, or has the product designed, developed or manufactured and markets it under its own name or trademark. The importer is the EU-established actor that places on the market a product bearing the name or trademark of a person established outside the Union. The distributor is the supply-chain actor, other than the manufacturer or importer, that makes the product available on the Union market without affecting its properties.

That distinction matters because the first EU supply is usually the placing-on-the-market event handled by the manufacturer or importer, while later reseller handoffs are usually making-available events handled by distributors.

An importer has CRA verification and stop-sale duties; it is more than the named recipient in a logistics chain.

Before placing the product on the market, the importer must ensure that the manufacturer has carried out the appropriate conformity assessment, drawn up the technical documentation, applied the CE marking, supplied the EU declaration of conformity and user information, and met the manufacturer identification and support-period information requirements referenced in Article 19.

If the importer considers or has reason to believe the product or the manufacturer processes are not in conformity, it must not place the product on the market until conformity is restored; if there is a significant cybersecurity risk, it must inform the manufacturer and market surveillance authorities.

A distributor has a due-care role even though it normally does not perform the manufacturer conformity assessment.

Before making a product with digital elements available, the distributor must verify that the product bears the CE marking and that the manufacturer and importer have provided the required documents and operator information referenced by Article 20.

If the distributor has reason to believe the product or manufacturer processes are not in conformity, it must not make the product available until conformity is restored. If the product poses a significant cybersecurity risk, it must inform the manufacturer and market surveillance authorities without undue delay.

Ordinary resale keeps the importer or distributor role.

The CRA treats an importer or distributor as the manufacturer if it places a product with digital elements on the market under its own name or trademark, or if it carries out a substantial modification of a product already placed on the market. In that situation, the actor becomes subject to the manufacturer obligations in Articles 13 and 14.

It is the manufacturer-facing conformity signal for the CRA and other applicable Union harmonisation legislation, not a cybersecurity rating or a mark of EU origin.

The CRA defines CE marking as the mark by which the manufacturer indicates that the product with digital elements and the manufacturer processes conform to the CRA essential cybersecurity requirements and to other applicable Union harmonisation legislation that provides for CE marking. The Blue Guide adds that CE marking is affixed after the relevant conformity assessment and declaration work, and that it is not a mark showing where the product was made.

It is the supply of a product with digital elements for distribution or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge.

Once a product has already been placed on the market, later supplies in the distribution chain are usually cases of making available, not new placing-on-the-market events.

Once per individual product.

The Blue Guide explains that placing on the market refers to each individual product, not to a model or type. That is why units of an existing model first placed on the market after new requirements apply must comply with the new rules.

No.

The Blue Guide explains that the first supply can be for payment or free of charge. What matters is that the product is complete and supplied for distribution, consumption or use on the Union market.

No.

The Blue Guide says placing on the market requires a completed product and an offer or agreement transferring ownership, possession or another property right, but it does not require physical handover.

No, not by itself.

Products kept in the stock of the manufacturer, the authorised representative or the importer are not yet placed on the market if they have not yet been supplied for distribution, consumption or use.

Yes.

The first supply for distribution on the Union market can still be a placing-on-the-market event even if it happens through the manufacturer's own commercial chain rather than through an unrelated distributor.