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Does the CRA apply to products already on the market?

It depends

It depends on modification. Products placed on the market before 11 December 2027 are subject to the Regulation only if substantially modified after that date, but Article 14 reporting obligations apply regardless [[F-004]] [[F-002]].

The deciding factors

Factors the rules engine reads for this fact pattern, and what each outcome means.
FactorIf trueIf falseSource
Already on the EU market before 11 December 2027Full requirements only on substantial modificationFull requirements apply from placing on the marketF-004
Change after placing on the market affects compliance or intended purposeSubstantial modification: full requirements applyNo triggerF-014
Customers or distributors ask for conformity evidenceCommercially expected, not yet legally requiredNo changeF-105
Article 14 reportingApplies from 11 September 2026 regardless—F-002

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Example scenarios

Each scenario is a fixture: the shared CEMarque rules engine evaluates its inputs at build time and the page cannot be served if the outcome shown here differs from the engine's.

Edge cases

Why

The legacy rule

Products placed on the market before 11 December 2027 are subject to the Regulation only if they are substantially modified after that date; Article 14 reporting obligations apply to them regardless [1]. The full requirements apply to everything else from 11 December 2027 [2].

Substantial modification

A substantial modification is a change to the product after it has been placed on the market that affects its compliance with the essential requirements or results in a modification of its intended purpose, and whoever makes it becomes the product's manufacturer [3]. Security fixes and maintenance releases that change neither are not substantial modifications; new functions that alter the intended purpose can be [3].

Reporting applies anyway

Article 14 reporting obligations of manufacturers apply from 11 September 2026, including for products already on the market [4] [1]. This is the clock legacy products cannot escape.

Commercial reality

Customers and distributors may ask for conformity evidence before it is legally required [5]. The scope check names both clocks for your product when you give its market position and date.

Timing

Article 14 reporting applies from 2026-09-11; full requirements apply only on substantial modification. Dates come from the Facts Table entries cited below, evaluated for the first example; run the check for your own product's dates.

What to do next

CRARequired only answers applicability. CEMarque carries your answers forward and adds your role, class, conformity route, dates, obligations, and a permanent cited verdict.

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Related applicability questions

Sources

  1. F-004 Products placed on the market before 11 December 2027 are subject to the Regulation only if substantially modified after that date; Article 14 applies to them regardless. Art. 69(2)–(3) EUR-Lex ↩
  2. F-003 The Regulation applies in full from 11 December 2027. Art. 71(2) EUR-Lex ↩
  3. F-014 Substantial modification: a change after placing on the market affecting compliance with essential requirements or resulting in a modification of the intended purpose; a person who substantially modifies a product becomes its manufacturer. Art. 3(30), Art. 22 EUR-Lex ↩
  4. F-002 Article 14 (reporting obligations of manufacturers) applies from 11 September 2026. Art. 71(2) EUR-Lex ↩
  5. F-105 For products already on the market, conformity is not required until substantial modification, but customers and distributors may ask for it; Article 14 applies regardless. Art. 69(2)–(3) EUR-Lex ↩
  6. F-005 A product with digital elements is a software or hardware product and its remote data processing solutions, including components placed on the market separately, whose intended purpose or reasonably foreseeable use includes a direct or indirect logical or physical data connection to a device or network. Art. 3(1), Art. 2(1) EUR-Lex ↩
  7. F-101 Made available on the market means supply for distribution or use on the EU market in the course of a commercial activity. Art. 3(22) EUR-Lex ↩

Facts v2026.09.4 · rules v2026.09.1 · page RP-301 v1 · last verified 25 September 2026 · reviewed by Claude (delegated by Ron) on 8 October 2026 · content 7bd435248613803a

CRARequired answers applicability only, using scope logic and cited regulatory facts maintained by CEMarque, which encodes Regulation (EU) 2024/2847 and published guidance as of Facts v2026.09.4 (10 September 2026). Results are "likely" or "conditional" readings of your answers, not a legal opinion and not a conformity assessment. Run the full cited determination on CEMarque before you act. Methodology.