Who is a manufacturer under the CRA?
Depends on your role
Depends on your role. A manufacturer develops or manufactures a product with digital elements, or has it designed, developed or manufactured, and markets it under their own name or trademark; rebranding someone else's product makes you the manufacturer too [[F-011]] [[F-106]].
The deciding factors
| Factor | If true | If false | Source |
|---|---|---|---|
| You sell it under your own name or brand | You are the manufacturer | Importer or distributor obligations instead | F-106 |
| You integrate components into your product | You are the manufacturer of the whole product | Component supplier is responsible for its component | F-104 |
| Supplied in the course of a commercial activity | Scope questions continue | Likely out of scope (or the open-source light regime) | F-007 |
| Has a direct or indirect connection to a device or network | It is a product with digital elements | Likely out of scope | F-005 |
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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Company that develops and sells its own app
Likely in scope · role: _
Develops the product and markets it under its own name: a manufacturer of a product with digital elements in scope.
Deciding fact: Art. 3(1), Art. 2(1)
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Retailer's own-label device made by a contract manufacturer
Likely in scope · role: _
Marketing under your own trademark makes you the manufacturer even though someone else built it.
Deciding fact: Art. 3(1), Art. 2(1)
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Wholesaler importing another brand's device
In scope — operator obligations differ by role · role: _
Not a manufacturer: an importer with a narrower set of obligations.
Deciding fact: Art. 3(1), Art. 2(1)
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Foundation stewarding a non-monetised open-source project
Open-source light regime may apply · role: _
Not a manufacturer: an open-source software steward under the light regime.
Deciding fact: Art. 3(14), Art. 3(48), Art. 24, Art. 64(10)(b), Recitals 18–19
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 definition
A manufacturer is a natural or legal person who develops or manufactures products with digital elements, or has them designed, developed or manufactured, and markets them under their name or trademark, whether for payment, monetisation or free of charge [1]. Two elements matter: causing the product to exist, and putting your name on it.
Own brand
Marketing a product under your own name or trademark makes you the manufacturer even if someone else developed it [2]. This is the rule that catches white-label ranges, rebranded partner software and contract manufacturing.
Integrators
A developer who integrates a component into their own product is the manufacturer of that product and responsible for its conformity, including the integrated component [3]. The component supplier remains responsible for the component as it placed it on the market [4].
Why the role matters here
Applicability is the same whoever you are; the role decides which obligations follow. Article 14 reporting obligations are the manufacturer's and apply from 11 September 2026 [5]. The full check on CEMarque takes the role from here and builds the obligation set on it.
Timing
Article 14 reporting applies from 2026-09-11; full requirements and CE marking apply from 2027-12-11. 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.
Check my product Run the full cited determination on CEMarque
Related applicability questions
Sources
- F-011 Manufacturer: a natural or legal person who develops or manufactures products with digital elements or has them designed, developed or manufactured, and markets them under their name or trademark, whether for payment, monetisation or free of charge. Art. 3(13) EUR-Lex ↩
- F-106 Marketing a product under your own name or trademark makes you the manufacturer even if someone else developed it. Art. 3(13), Art. 21 EUR-Lex ↩
- F-104 A developer who integrates a component into their own product is the manufacturer of that product and responsible for its conformity, including the integrated component. Art. 13(5), Art. 3(13) 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-002 Article 14 (reporting obligations of manufacturers) applies from 11 September 2026. Art. 71(2) EUR-Lex ↩
- F-009 Free and open-source software not monetised is not considered placed on the market. Open-source software stewards (legal persons that systematically support free and open-source software intended for commercial activities) have a light regime: a documented cybersecurity policy, cooperation with authorities, and Article 14 reporting only where they are involved in development or where an incident affects their own development infrastructure; they do not affix CE marking and are not subject to fines. Art. 3(14), Art. 3(48), Art. 24, Art. 64(10)(b), Recitals 18–19 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 ↩
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.