Search every question across CRA sub-FAQs

No.

The Blue Guide says repeated renting of the same product does not create a new placing-on-the-market event. The compliance moment remains the first renting or other first supply of that individual product.

No, provided the Blue Guide and CRA conditions are met.

The Blue Guide treats products displayed or operated under controlled conditions at trade fairs, exhibitions or demonstrations as not yet placed on the market, as long as they are clearly identified as non-compliant and not yet available for placing on the market. The CRA contains the same type of carve-out for products, including prototypes, presented or used at such events.

Yes, but only under a narrow CRA exception.

Article 4(3) allows unfinished software such as alpha versions, beta versions or release candidates to be made available on the market for the limited period required for testing, provided it carries a visible sign stating that it does not comply and is not available for purposes other than testing. Recital 37 also says manufacturers should not force users to upgrade to versions released only for testing purposes.

Because the CRA uses the same NLF documentation logic.

The Blue Guide explains the role of technical documentation and the possibility of a single declaration of conformity dossier across several Union acts. The Commission's CRA FAQ relies on that same logic when explaining what technical documentation must contain and how the declaration of conformity works under the CRA.

Because the CRA uses the same product-law logic that compliance cannot be assessed only against the manufacturer's preferred use case.

The Commission's CRA FAQ relies on Blue Guide concepts to explain that the cybersecurity risk assessment must take account of intended purpose, reasonably foreseeable use and reasonably foreseeable misuse, and that those choices also affect the user information that has to be provided.

For software, the CRA follows the same NLF concepts, but the draft Commission guidance explains how they work in a digital delivery model.

According to the draft guidance, once the software manufacturing phase is complete and a given software product is first offered for distribution or use on the Union market in the course of a commercial activity, that software product is regarded as placed on the market. Later downloads or remote access to that same unchanged software product are instances of making available rather than fresh placing-on-the-market events.

No.

The draft guidance says later iterations that do not qualify as substantial modifications do not trigger a new conformity assessment and do not change the software product's date of placement on the market. A new placing-on-the-market date arises only where the later iteration qualifies as a substantial modification.

No.

The draft guidance says the "first offering creates the placing-on-the-market date" logic applies only to standalone software supplied via digital means. If the software is supplied on a USB flash drive or other physical medium, the physical item is the product supplied for distribution. If software is necessary for hardware to perform its intended functions, the hardware and that software together form the product placed on the market.

Under the CRA, the CE marking is the manufacturer's visible indication that the product with digital elements, and the processes put in place by the manufacturer, conform to the CRA's essential cybersecurity requirements and to any other applicable Union harmonisation legislation that also provides for CE marking.

It is the visible consequence of the conformity-assessment process. It is not a separate licence or approval stamp issued by authorities.

It supports free circulation by signalling presumed compliance with the applicable CE-marking legislation.

The Blue Guide explains that products bearing the CE marking are presumed to comply with the applicable Union harmonisation legislation and therefore benefit from free circulation. The CRA follows the same logic: Member States must not impede the making available on the market of products that comply with the Regulation, and recital 36 links that free movement function to CRA CE marking.

Yes, as the general rule for products with digital elements that are placed on the Union market under the CRA.

The manufacturer must affix the CE marking before placing the product on the market, after the applicable conformity assessment has been completed. The Blue Guide also makes clear that products not covered by Union legislation providing for CE marking must not bear the CE marking.

No, not as a general rule.

The CE marking remains the manufacturer's declaration of conformity on its sole responsibility. Some CRA conformity-assessment routes involve a notified body, but the CE marking does not by itself mean that a public authority approved the product.

No.

The CE marking indicates conformity with the applicable legislation. It is not a mark of origin and does not show where the product was manufactured.

The manufacturer may affix it, and the Blue Guide also recognises affixing by an authorised representative acting on the manufacturer's behalf.

Even where an authorised representative is used, the manufacturer remains ultimately responsible for conformity and for the CE marking.

Yes.

Under the CRA, an importer or distributor that places a product on the market under its own name or trademark, or that carries out a substantial modification, is treated as the manufacturer. A different natural or legal person that substantially modifies a product and makes it available on the market can also become the manufacturer for the affected product or part. The Blue Guide reflects the same general NLF logic.

Before the product with digital elements is placed on the market.

That means the manufacturer cannot defer CE marking until after launch or leave it to later stages in the distribution chain.

No.

The manufacturer must first complete the applicable conformity assessment procedure with a positive result. The CRA FAQ states this directly, and the Blue Guide says the CE marking may not, in principle, be affixed until the conformity assessment has been completed.

As a rule, it must be affixed visibly, legibly and indelibly to the product itself.

If that is not possible or not warranted because of the nature of the product, the CRA requires it to be affixed to the packaging and to the EU declaration of conformity accompanying the product.

No.

The Blue Guide is clear that moving the CE marking off the product cannot be justified on purely aesthetic grounds. The exception is only for cases where affixing it to the product is not possible or not warranted because of the product's nature.

No.

Under Article 30(1), the CRA gives the website option only for products with digital elements in the form of software. For other products, the rule is product first, with packaging and accompanying EU declaration of conformity as the fallback where the nature of the product justifies it.