Does the CRA apply to a non-EU company selling into the EU?
Likely yes
Likely yes. The Regulation follows the product onto the EU market, not the manufacturer's address: a connected product supplied commercially to EU customers is a product with digital elements in scope, and a non-EU manufacturer may appoint an authorised representative [[F-101]] [[F-005]] [[F-034]].
The deciding factors
| Factor | If true | If false | Source |
|---|---|---|---|
| Made available on the EU market | Scope questions continue | Likely out of scope | F-101 |
| Manufacturer established outside the EU | An authorised representative may be appointed by written mandate | Not applicable | F-034 |
| An EU business first places it on the EU market | That business is the importer | Direct supply: the manufacturer alone | F-012 |
| 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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US software vendor selling licences directly to EU companies
Likely in scope · role: _
The product is made available on the EU market; the vendor is the manufacturer wherever it is established.
Deciding fact: Art. 3(1), Art. 2(1)
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Asian hardware maker selling through an EU importer
Likely in scope · role: _
In scope as the manufacturer; the EU importer carries importer obligations alongside.
Deciding fact: Art. 3(1), Art. 2(1)
-
The EU importer of that hardware, checking its own position
In scope — operator obligations differ by role · role: _
The product is in scope; the importer holds obligations to verify the manufacturer's conformity work.
Deciding fact: Art. 3(1), Art. 2(1)
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Non-EU vendor with no EU sales at all
Likely out of scope · role: _
Not made available on the EU market, so the Regulation does not apply.
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
Scope follows the product
Made available on the market means supply for distribution or use on the EU market in the course of a commercial activity [1]. A manufacturer is whoever develops or has the product developed and markets it under their own name, wherever they are established [2]. A non-EU company whose product reaches EU customers is therefore in scope for that product [3] [1].
Authorised representative
A manufacturer may appoint an authorised representative by written mandate; the representative keeps the declaration of conformity and technical documentation available and cooperates with authorities [4]. Appointing one does not move the manufacturer's obligations; it provides an EU point of contact for them.
Importers
Where an EU business first places the non-EU product on the EU market, that business is an importer and must place only compliant products on the market, verifying the manufacturer's conformity assessment, documentation and marking [5]. The manufacturer and the importer are both in the chain; each runs the check for its own role.
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-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 ↩
- 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-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-034 A manufacturer may appoint an authorised representative by written mandate; the representative keeps the declaration of conformity and technical documentation at the disposal of authorities and cooperates with them. Non-EU manufacturers: reporting is routed via the representative's Member State. Art. 18, Art. 3(15), Art. 14(7) EUR-Lex ↩
- F-012 Importers place only compliant products on the market; verify conformity assessment, technical documentation, CE marking and manufacturer identification; indicate their own name and address; report known vulnerabilities to the manufacturer; keep the declaration of conformity; cooperate with authorities. Art. 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.