Find the exact question, open the source answer card, and copy a direct link to the anchored sub-FAQ response.
No.
Five years is the minimum in normal cases, not the automatic answer for every product. The CRA says the support period must be at least five years unless the product is expected to be in use for less than five years. If the product is reasonably expected to remain in use for longer than five years, the support period should be longer.
Article 13(8), recital 60
section 4.5.2
points 114-115
The CRA requires manufacturers to consider:
- reasonable user expectations
- the nature of the product, including its intended purpose
- relevant Union law determining the product's lifetime
The CRA also allows manufacturers to take into account:
- support periods of similar products
- availability of the operating environment
- support periods of third-party integrated components that provide core functions
- guidance from ADCO and the Commission
These factors must be applied proportionately.
Article 13(8)
section 4.5.1
point 114
Not in one sentence using the words "the support period starts on X date". But the combined reading of the CRA, the Commission FAQ, the draft guidance, and the Blue Guide points to placing on the market as the operative starting point.
Why:
- Article 13(8) requires vulnerability handling when placing the product on the market and for the support period.
- Article 13(19) requires the end date to be disclosed at the time of purchase.
- The Commission FAQ gives a hardware example counting from units placed on the market in January 2028 to January 2033.
- The draft guidance gives an example of eight years from the date of placement on the market.
Article 13(8), Article 13(19)
section 4.5.3
Example 46
For physical products, it is tied to each individual product, not to the abstract model or type.
The Blue Guide says placing on the market refers to each individual product, not to a type of product, whether it is manufactured individually or in series. The Commission FAQ then applies that logic to CRA support periods for hardware.
section 2.3
sections 4.5.3 and 7.2
Yes.
The Commission FAQ gives this directly. Units of a hardware model placed on the market in January 2028 with a five-year support period can remain supported until January 2033. If more units of the same model are placed on the market on 1 January 2030, the manufacturer must set the support period for those newly placed units too.
section 4.5.3
section 2.3
Yes.
The Commission FAQ says products already placed on the market can continue to be made available after the support period expires. But if new units of that product are placed on the market later, the manufacturer must set the support period for those newly placed units.
section 4.5.3
sections 2.2-2.3
No.
For physical products, manufacturing must be complete before placing on the market can happen, but manufacturing completion alone is not enough. There must also be a first supply for distribution or use on the Union market.
For standalone software supplied digitally, the draft guidance also rejects manufacturing completion alone as enough. Placement occurs when the completed software is first supplied for distribution or use on the EU market.
section 2.3
points 13-14
No.
The Blue Guide says placing on the market requires an offer or agreement for transfer of ownership, possession, or another property right after manufacturing is complete. It expressly says physical handover is not required.
section 2.3
Usually yes.
The Blue Guide says that when a manufacturer or importer first supplies a product to a distributor or an end-user, that first supply is placing on the market. Later transactions further down the chain are making available, not a new placing event.
section 2.3
No.
Once that individual unit has already been placed on the market, later distributor-to-distributor or distributor-to-end-user transactions are only later instances of making the product available on the market.
section 2.3
section 4.5.3
No.
The CRA support-period logic is anchored to placing on the market, not first use. The Blue Guide treats placing on the market and putting into service as different concepts. The CRA materials on support periods use placing on the market as the reference point.
sections 2.3 and 2.6
Article 13(8)
Example 46
No.
The Blue Guide treats them as distinct concepts. Some Union legislation uses both concepts, or treats own use as equivalent. The CRA support-period rules and the available Commission materials are built around placing on the market, not putting into service.
sections 2.3 and 2.6
Article 13(8)
No.
The Blue Guide says placing on the Union market can happen only once for each individual product across the EU and does not happen separately in each Member State.
section 2.3
Generally no.
The Blue Guide says placing on the market does not occur where a product is manufactured for one's own use, unless the relevant Union legislation also covers own use.
section 2.3
No.
The Blue Guide says an offer or agreement concluded before manufacture is finalised cannot be treated as placing on the market. Manufacturing must be complete first.
section 2.3
That can be the placing-on-the-market event.
The Blue Guide explains that for direct distance sales from outside the EU to an EU end user, the product is placed on the market when the order is placed and confirmed for a specific product that is already manufactured and ready to be shipped.
section 2.3
They can change the answer.
The Blue Guide says:
- products offered online to EU end users are deemed made available if the offer targets the Union
- but the actual placing-on-the-market event depends on the distribution chain
- if products are shipped into the EU and stored with a fulfilment service provider for EU delivery, they are considered placed on the market when released for free circulation
- if a specific already-manufactured product is sold directly from outside the EU to an EU end user, placement occurs when the order is placed and confirmed for that specific product
sections 2.3-2.4
section 4.2.3
No.
The Blue Guide treats those situations as different from placing on the Union market. Compliance with Union product rules applies when the product is actually placed on the market.
section 2.3
Not always.
The Blue Guide distinguishes between:
- being deemed made available for market-surveillance purposes when the offer targets EU end users, and
- the actual placing-on-the-market event for the individual product, which depends on the distribution chain
So the targeted offer matters, but the placement date still depends on how that individual product reaches the EU market.
section 2.4
That does not delay the placement date.
The Commission FAQ recognizes this situation directly. A product may sit in the manufacturer's distribution branch, in fulfilment arrangements, or on a retailer shelf before reaching the user. It was still placed on the market earlier.
section 4.2.3
section 2.3