Does the CRA apply to spare parts?
It depends
It depends on whether the part is identical. Spare parts made available to replace identical components in products with digital elements are excluded; a part that adds or changes functions is a component placed on the market separately and in scope [[F-010]] [[F-005]].
The deciding factors
| Factor | If true | If false | Source |
|---|---|---|---|
| Made available only to replace an identical component | Excluded | In scope as a component | F-010 |
| The part adds or changes functions | Component placed on the market separately | Identical replacement | F-005 |
| Installing it substantially modifies a legacy product | Full requirements may be triggered for the product | No change | F-014 |
| Supplied in the course of a commercial activity | Scope questions continue | Likely out of scope (or the open-source light regime) | F-007 |
Check your own product
Start the short scope check. Every legally material fact — EU availability, commercial activity, exclusions, your role — is asked, never assumed.
Example scenarios
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Identical replacement control board supplied to repairers
Likely out of scope · role: _
Made available to replace an identical component: excluded.
Deciding fact: Art. 2(2)–(4), (6)–(7)
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Upgrade module that adds Wi-Fi to an older appliance
Likely in scope · role: _
Adds a function, so it is a component placed on the market separately and in scope.
Deciding fact: Art. 3(1), Art. 2(1)
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Spare part supplied only outside the EU
Likely out of scope · role: _
Not made available on the EU market.
Deciding fact: Art. 3(22)
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
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Why
The spare-part exclusion
Spare parts made available on the market to replace identical components in products with digital elements, manufactured to the same specifications as the components they replace, are excluded from the Regulation [1]. In practice, it lets an existing product be kept running without each identical replacement part becoming a new product in scope [1].
Identical is the test
A part that adds a function, changes the intended purpose or connects in a way the original did not is not an identical replacement; it is a component placed on the market separately and a product with digital elements in its own right [2]. Newer firmware that performs the same function to the same specification does not by itself change that; new functions do.
Effect on the host product
Installing a non-identical part in a product already on the market can be a substantial modification if it affects compliance with the essential requirements or modifies the intended purpose, which brings the full requirements onto that product [3]. The scope check considers the part you supply; the full determination on CEMarque covers the product it goes into.
Commercial supply
Spare parts are in commerce; the exclusion, not the absence of commercial activity, is what takes identical replacements out [4] [1].
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.
Check my product Run the full cited determination on CEMarque
Related applicability questions
Sources
- F-010 Excluded: medical devices (Regulation (EU) 2017/745) and in vitro diagnostics (2017/746) and motor-vehicle type-approved products (2019/2144) (Art. 2(2)); civil aviation products certified under Regulation (EU) 2018/1139 (Art. 2(3)); marine equipment under Directive 2014/90/EU (Art. 2(4)); spare parts made to identical specifications (Art. 2(6)); products developed or modified exclusively for national security or defence, or designed exclusively to process classified information (Art. 2(7)). Art. 2(2)–(4), (6)–(7) EUR-Lex ↩
- 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 ↩
- 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 ↩
- F-007 The Regulation applies to products made available on the market in the course of a commercial activity; charging a price, charging for support, monetising via advertising or data, or otherwise intending to monetise are commercial activity. Art. 2(1), Art. 3(22), Recitals EUR-Lex ↩
- 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 ↩
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.