Does the CRA apply to white-label products sold under my brand?
Likely yes
Likely yes, and you are the manufacturer. Marketing a product under your own name or trademark makes you the manufacturer even if someone else developed it, and a connected product sold commercially in the EU is a product with digital elements [[F-106]] [[F-005]].
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 |
| Made available on the EU market | Scope questions continue | Likely out of scope | F-101 |
| 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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Retailer's own-label smart plug made by a contract supplier
Likely in scope · role: _
The retailer markets the product under its own name and is the manufacturer for the Regulation's purposes.
Deciding fact: Art. 3(1), Art. 2(1)
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SaaS vendor rebrands a partner's desktop client under its own name
Likely in scope · role: _
Marketing under your own trademark makes you the manufacturer of the product with digital elements.
Deciding fact: Art. 3(1), Art. 2(1)
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Reseller keeps the original manufacturer's brand and imports from outside the EU
In scope — operator obligations differ by role · role: _
The product is in scope; without rebranding, the reseller is an importer with importer obligations.
Deciding fact: Art. 3(1), Art. 2(1)
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Own-brand product sold only outside the EU
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
The brand decides the role
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 [1]. Marketing a product under your own name or trademark makes you the manufacturer even if someone else developed it [2]. Contract manufacturing, rebranding a partner's client and retailer own-label ranges all fall here.
What that means for applicability
The product is a product with digital elements if it is connected software or hardware supplied commercially in the EU [3] [4]. The white-label arrangement does not change applicability; it decides who carries the manufacturer's obligations. Your supplier's own conformity work may help, but the responsibility for the product as marketed under your brand is yours [2].
Resellers who keep the original brand
A business that brings another brand's product into the EU without rebranding is an importer, and one that resells within the EU is a distributor; each has its own, narrower set of obligations rather than the manufacturer's [5] [6]. The scope check reports the apparent role from your answers.
Integrated components
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 [7].
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-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-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-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-013 Distributors act with due care; verify CE marking, declaration of conformity and manufacturer/importer obligations; do not make non-compliant products available; report vulnerabilities to the manufacturer; cooperate with authorities. Art. 20 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-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.