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Across 40 modules • Updated Mar 10, 2026
Author
Sorena AI
Published
Mar 10, 2026
Updated
Mar 10, 2026
CRA Manufacturer Obligations

How does the manufacturer determine and disclose the support period?

Article 13(8) says the support period must reflect the time during which the product is expected to be in use. The manufacturer must take into account reasonable user expectations, the nature of the product including its intended purpose, and relevant Union law determining product lifetime. The support period must be at least five years unless the product is expected to be in use for less than five years.

The manufacturer must include in the technical documentation the information taken into account to determine the support period. Article 13(19) also requires the manufacturer to clearly and understandably specify the end date of the support period, at least month and year, at the time of purchase in an easily accessible manner and, where applicable, on the product, packaging, or by digital means.

Citations
Cyber Resilience Act

Article 13(8) defines support-period criteria and minimum duration; Article 13(19) requires support-period end-date disclosure.

CRA Manufacturer Obligations

How long must security updates remain available?

Each security update made available during the support period must remain available for at least 10 years after it is issued or for the remainder of the support period, whichever is longer.

For evidence controls, keep the update identifier, affected product versions, vulnerability or risk addressed, release date, distribution channel, integrity mechanism, user notification, and archive or availability proof. Those records help connect Article 13(9), Annex I Part II, and user-instruction obligations.

Citations
Cyber Resilience Act

Article 13(9) sets the availability period for security updates issued during the support period.

CRA Manufacturer Obligations

What technical documentation and declaration records must the manufacturer keep?

Before placing the product on the market, the manufacturer must draw up technical documentation, carry out the applicable conformity assessment procedure or have it carried out, draw up the EU declaration of conformity once conformity is demonstrated, and affix the CE marking.

The manufacturer must keep the technical documentation and EU declaration of conformity for at least 10 years after placing the product on the market or for the support period, whichever is longer. Annex VII points the evidence set toward the product description, design and development information, production and vulnerability-handling information, the cybersecurity risk assessment, applied standards or specifications, conformity assessment material, and support-period determination.

Citations
Cyber Resilience Act

Article 13(12)-(13), Article 28, Article 30, Article 32, and Annex VII cover documentation, declaration, conformity assessment, CE marking, and retention.

CRA Manufacturer Obligations

What does CRA CE marking mean for the manufacturer?

CE marking is the manufacturer's visible declaration that the product satisfies the applicable Union harmonisation requirements requiring that marking and that the relevant conformity assessment procedure has been completed. Under the CRA, the manufacturer affixes the CE marking only after the applicable conformity assessment route has demonstrated conformity.

The CRA does not make CE marking a separate cybersecurity test result. It sits at the end of the manufacturer's evidence chain: risk assessment, Annex I implementation, vulnerability-handling procedures, technical documentation, conformity assessment, EU declaration of conformity, and continuing support-period controls.

Citations
Cyber Resilience Act

Article 13(12), Article 30, and Article 32 require conformity assessment and CE marking before market placement.

Blue Guide 2022

The CE-marking FAQ explains what CE marking indicates and that it follows the relevant conformity assessment procedure.

CRA Manufacturer Obligations

What user information and contact details must the manufacturer provide?

The manufacturer must ensure product identification is available through a type, batch, serial number, or other identifying element. It must also provide its name, trade name or trademark, postal address, and email address or other digital contact details, and where applicable a website.

Article 13 also requires a single point of contact so users can communicate directly and rapidly with the manufacturer, including for vulnerability reporting. The product must be accompanied by Annex II information and instructions in a language easily understood by users and market surveillance authorities, with enough clarity to allow secure installation, operation, and use.

Citations
Cyber Resilience Act

Article 13(15)-(18) and Annex II cover product identification, manufacturer contact details, vulnerability contact, and user instructions.

CRA Manufacturer Obligations

When must a manufacturer report vulnerabilities and incidents under the CRA?

Article 14 requires manufacturers to notify actively exploited vulnerabilities and severe incidents having an impact on the security of the product with digital elements. The CRA reporting clock starts when the manufacturer becomes aware.

The staged deadlines are an early warning within 24 hours and a fuller notification within 72 hours. The final report deadline differs: for an actively exploited vulnerability, it is no later than 14 days after a corrective or mitigating measure is available; for a severe incident, it is within one month after the incident notification. Article 14 also requires impacted users, and where appropriate all users, to be informed about the vulnerability or incident and risk-mitigation or corrective measures users can deploy.

Citations
Cyber Resilience Act

Article 14(1)-(4) sets notification duties and staged deadlines; Article 14(8) covers user information.

CRA Manufacturer Obligations

What happens if the manufacturer knows or has reason to believe the product is not in conformity?

From market placement and during the support period, the manufacturer must immediately take the corrective measures necessary to bring the product or the manufacturer's processes into conformity, or withdraw or recall the product as appropriate.

The evidence record should show the trigger, affected product versions or batches, risk assessment update, corrective or mitigating measure, user and authority communications, disposition decision, and verification that the product or process was brought back into conformity.

Citations
Cyber Resilience Act

Article 13(21) requires corrective measures, withdrawal, or recall when the manufacturer knows or has reason to believe the product is not in conformity.

CRA Manufacturer Obligations

What evidence should be ready for a market surveillance authority?

On reasoned request, the manufacturer must provide all information and documentation necessary to demonstrate conformity, in paper or electronic form and in a language easily understood by the market surveillance authority. It must also cooperate with measures taken to eliminate cybersecurity risks posed by the product.

A useful CRA manufacturer evidence pack includes the product scope and role analysis, cybersecurity risk assessment and updates, Annex I applicability and implementation matrix, component due-diligence records, vulnerability-handling policy and cases, support-period rationale, technical documentation, conformity-assessment outputs, EU declaration of conformity, CE-marking evidence, user instructions, support-period disclosure, update availability records, Article 14 reporting records, and corrective-action records.

Citations
Cyber Resilience Act

Article 13(7), Article 13(13), Article 13(22), and Annex VII support the evidence-control set for manufacturer conformity.

CRA Manufacturer Obligations

Can the manufacturer delegate Article 13 obligations to an authorised representative or subcontractor?

No for the core Article 13 duties. Article 18(2) says the obligations in Article 13(1) to (11), Article 13(12) first subparagraph, and Article 13(14) cannot form part of the authorised representative's mandate.

Authorised representatives, suppliers, hosted-service providers, subcontractors, distributors, and component maintainers can support the evidence chain, but the manufacturer still needs control over the product, documentation, conformity assessment, vulnerability handling, support-period decisions, and authority cooperation.

Citations
Cyber Resilience Act

Article 18(2) excludes core manufacturer duties from the authorised representative mandate.

Blue Guide 2022

Section 3.1 explains the manufacturer's continuing responsibility when work is subcontracted.

CRA Manufacturer Obligations

What should change-control teams treat as CRA manufacturer evidence controls?

Treat product changes, dependency changes, vulnerability findings, support-period changes, new market placements, conformity-assessment changes, and user-instruction changes as evidence events. Each event should update the relevant CRA record rather than remain only in engineering tickets.

The minimum useful record is the affected product and version, manufacturer role, Article 13 or Annex I control affected, risk-assessment impact, component impact, conformity-assessment impact, user-information impact, support-period impact, release or remediation decision, source evidence, approver, and retained artifact location.

Citations
Cyber Resilience Act

Article 13(2), Article 13(7), Article 13(14), Article 13(21), and Annex VII support lifecycle evidence updates.

CRA Market Surveillance and Enforcement

Who enforces the CRA on the market?

Member States do, through their designated market surveillance authorities.

The CRA requires each Member State to designate one or more market surveillance authorities, and it makes the general Union market-surveillance framework in Regulation (EU) 2019/1020 applicable to products within the CRA's scope.

Citations
Cyber Resilience Act

Article 52(1)-(2) applies Regulation (EU) 2019/1020 and requires Member States to designate CRA market-surveillance authorities.

CRA Market Surveillance and Enforcement

Does the CRA create a separate enforcement system from general EU market-surveillance law?

No.

The CRA uses the existing Union market-surveillance framework rather than creating a completely standalone enforcement system. Article 52(1) expressly makes Regulation (EU) 2019/1020 applicable to products with digital elements covered by the CRA.

Citations
Cyber Resilience Act

Article 52(1) makes the EU market-surveillance framework apply to CRA products with digital elements.

CRA Market Surveillance and Enforcement

Who is responsible for CRA market surveillance when the product is also a high-risk AI system?

For those products, the market-surveillance authorities designated under the AI Act are responsible for the CRA market-surveillance activities.

They still have to cooperate, as appropriate, with the market-surveillance authorities designated under the CRA and, for Article 14 reporting supervision, with the CSIRTs designated as coordinators and ENISA.

Citations
Cyber Resilience Act

Article 52(14) assigns CRA market surveillance for high-risk AI systems to the AI Act market-surveillance authorities, with cooperation duties.

CRA Market Surveillance and Enforcement

Are open-source software stewards also supervised through CRA market surveillance?

Yes.

The authorities designated under Article 52 are also responsible for market-surveillance activities relating to the obligations imposed on open-source software stewards under Article 24. If a steward is non-compliant, the authority must require appropriate corrective action.

Citations
Cyber Resilience Act

Articles 24 and 52(3) place open-source software steward obligations within the CRA market-surveillance remit.

CRA Market Surveillance and Enforcement

Do CRA market-surveillance authorities have to cooperate with other regulators?

Yes.

The CRA requires cooperation, where relevant, with national cybersecurity certification authorities, CSIRTs designated as coordinators, ENISA, market-surveillance authorities under other Union product laws, and authorities supervising Union data-protection law.

Citations
Cyber Resilience Act

Article 52(4)-(7) sets cooperation duties with certification, CSIRT, ENISA, product-law, and data-protection authorities.

CRA Market Surveillance and Enforcement

Can complaints, vulnerability reports, or other outside signals trigger enforcement attention?

Yes.

The CRA requires authorities to inform consumers where to submit complaints indicating possible non-compliance and where and how to access mechanisms for reporting vulnerabilities, incidents, and cyber threats affecting products with digital elements. Because the CRA applies the Union market-surveillance framework in Regulation (EU) 2019/1020, the Blue Guide also states that complaints must be followed up appropriately and that consumer complaints, media reports, incidents, and similar information can feed the authorities' risk-based choice of online and offline checks.

But a complaint or report does not by itself establish infringement. Any corrective or restrictive measure still has to rest on the legal findings required under the CRA procedures.

Citations
Cyber Resilience Act

Article 52(11) requires consumer complaint and vulnerability-reporting information; Articles 54, 57 and 58 govern resulting measures.

Blue Guide 2022

Sections 7.3.3 and 7.4.1 explain complaint follow-up and risk-based market-surveillance checks.

CRA Market Surveillance and Enforcement

Can CRA market-surveillance authorities provide guidance as well as enforce?

Yes.

The CRA expressly allows market-surveillance authorities to provide guidance and advice to economic operators on implementation, with support from the Commission and, where appropriate, CSIRTs and ENISA.

Citations
Cyber Resilience Act

Article 52(10) allows market-surveillance authorities to provide implementation guidance and advice to economic operators.

CRA Market Surveillance and Enforcement

What can trigger a formal CRA product evaluation by a national authority?

A national authority can open the Article 54 procedure where it has sufficient reason to consider that a product with digital elements, including its vulnerability handling, presents a significant cybersecurity risk.

The evaluation concerns compliance with all CRA requirements, not just one suspected defect.

Citations
Cyber Resilience Act

Article 54(1) sets the significant-cybersecurity-risk trigger for a national evaluation.

CRA Market Surveillance and Enforcement

Does "significant cybersecurity risk" include non-technical factors?

Yes.

When determining the significance of a cybersecurity risk, authorities must also consider non-technical risk factors, in particular those identified through Union-level coordinated security risk assessments of critical supply chains under NIS 2.

Citations
Cyber Resilience Act

Articles 54(2) and 56(2) require non-technical risk factors to be considered when assessing significant cybersecurity risk.

CRA Market Surveillance and Enforcement

What must economic operators do during a CRA investigation?

They must cooperate with the market-surveillance authority as necessary.

The CRA also allows authorities to request technical support from a CSIRT designated as coordinator or from ENISA when implementing or enforcing the Regulation and when evaluating compliance under Article 54.

Citations
Cyber Resilience Act

Articles 52(5) and 54(1) support technical assistance requests and require economic-operator cooperation.

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