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No.

The Commission FAQ says distributors are not required to bring such products into CRA compliance merely because the general application date has passed. The key transition point is still whether the individual product was placed on the market before 11 December 2027. The main exception remains reporting under Article 14, and a separate trigger exists if someone substantially modifies the product after that date.

No.

Once 11 December 2027 arrives, products first placed on the market on or after that date must comply with the CRA as applicable. The Transition Period helps manufacturers prepare, but it does not create an extra post-application grace period for newly placed products.

The practical transition question is not whether the CRA already applies to the product today, but when the individual product will first be placed on the market and what evidence will be needed by that date.

The CRA phased dates and the Commission FAQ together point to a simple planning structure:

- be ready for Article 14 reporting from 11 September 2026

- be ready for full CRA compliance for products first placed on the market from 11 December 2027

- treat existing third-party certificates only as partial evidence for the risks they actually cover, and only within their validity window

No.

The Blue Guide says products in the stocks of the manufacturer or importer are not yet placed on the market if they have not yet been supplied for distribution, consumption, or use on the Union market. The Commission FAQ then applies that logic specifically to the CRA transition: only individual products actually placed on the market before 11 December 2027 avoid the CRA's full application, while later-placed units of the same type must comply.

So manufacturing a unit before 11 December 2027 is not enough by itself. If that unit is first placed on the market on or after 11 December 2027, it must comply with the CRA as applicable.

No.

The Blue Guide says products introduced from a third country but still in transit, in free zones, in warehouses, in temporary storage, or under other special customs procedures are not yet placed on the Union market. The CRA transition therefore does not turn on the shipment date or on the fact that the goods have already entered the customs territory. The relevant question is when they are first made available on the Union market.

If those goods are only released for free circulation and first supplied on the Union market on or after 11 December 2027, the CRA timing is assessed at that later moment.

For standalone software supplied digitally, the relevant date is the first offering for distribution or use on the EU market.

The draft Commission guidance says a standalone software version is placed on the market when its manufacturing phase is complete and that version is first supplied for distribution or use on the EU market in the course of a commercial activity. Later downloads or remote access to the same version are instances of making that software available, not new placements on the market. The same is true for later iterations that do not qualify as substantial modifications.

That means a standalone software version first offered before 11 December 2027 is not newly placed on the market again merely because users download that unchanged or non-substantially modified version after that date. But if a later iteration is a substantial modification, that later version is treated as newly placed on the market and must comply accordingly.

No.

The CRA transition does not grandfather products merely because the commercial contract, procurement cycle, or development project started before 11 December 2027. The legal trigger remains when the individual product is first placed on the market. The draft Commission guidance expressly notes that some complex systems may involve contracts signed before the CRA applies, but the manufacturer must still ensure before placement on the market that the conformity assessment has been carried out, the EU declaration of conformity has been drawn up, and the CE marking affixed.

The same draft guidance also explains that long design cycles and existing technical constraints do not remove complex systems from the CRA. Instead, those constraints belong in the cybersecurity risk assessment and technical documentation, with alternative or compensatory mitigations where a specific requirement cannot be fulfilled through state-of-the-art measures.

Yes, unless they are substantially modified from that date.

Article 69(2) preserves the status of products already placed on the market before 11 December 2027. The March 2026 draft guidance states that products placed on the market before that date remain subject to the Union legislation applicable at the time of their placing on the market and, if they were compliant then, they can continue to be sold and put into operation unless they are substantially modified on or after 11 December 2027.

The main CRA transition exception is Article 14 reporting, which still applies to in-scope products already placed on the market before 11 December 2027.

Manufacturers of in-scope products should be able to recognise an actively exploited vulnerability or severe incident, establish when the manufacturer became aware, identify affected products and versions, and submit the staged Article 14 notifications through the single reporting platform within the applicable deadlines.

The process also needs a user-communication path for impacted users and, where appropriate, all users. These reporting duties apply to in-scope products placed on the market before 11 December 2027 as well as later products, so a legacy-product inventory, reporting ownership, evidence-preservation rules, and escalation contacts should be ready before 11 September 2026.

Yes.

The CRA requires each security update that was made available during the support period to remain available after issuance for at least 10 years or for the remainder of the support period, whichever is longer.

No.

The support period is the period during which the manufacturer must handle vulnerabilities effectively. Update availability is a separate rule that keeps already-issued security updates accessible for a minimum period after issuance.

Yes.

Article 13(9) applies to each security update that has been made available to users during the support period.

No.

Article 13(9) is framed at the level of each security update made available during the support period, not only the latest one.

Yes.

A product might have a shorter support period, but a security update issued during that period may still need to remain available for at least 10 years after issuance if that is longer.

Not necessarily.

The obligation to handle vulnerabilities runs through the support period. Article 13(9) separately preserves access to security updates that were already issued during that period.