Step 1 of 3 in Am I even in scope?
Research: referenced in the ENISA SME CRA Survey 2026.
The CRA assigns different obligations to manufacturers, importers, distributors, authorised representatives and OSS stewards. Answer six yes/no questions grounded in the regulation's own definitions and see which roles apply to you — an organisation can hold more than one at the same time.
Do you place products with digital elements on the EU market under your own name or trademark?
That's the defining test for a CRA manufacturer. Art. 3(13)
Do you substantially modify another manufacturer's product or place it on the EU market under your name before onward supply?
A substantial modification makes you the CRA manufacturer of the resulting product. Art. 22
Are you established in the EU and place products on the EU market that bear the name or trademark of a manufacturer established outside the EU?
Only entities in the EU that bring in non-EU-branded products count as CRA importers. Art. 3(16)
Do you make products with digital elements available on the EU market without being their manufacturer or importer?
Typical distributor: retailer, reseller, wholesaler that is neither the maker nor the importer. Art. 3(17)
Are you established in the EU and hold a written mandate from a non-EU manufacturer to act on their behalf?
Only a written mandate turns an advisor into an authorised representative. Art. 3(15)
Are you a legal person who systematically and sustainably develops or contributes to free and open-source software placed on the EU market — without being its manufacturer?
OSS stewards fall under a softer regime specifically designed for foundations and communities. Art. 3(14)