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 own name or trademark, whether for payment, monetisation, or free of charge. This is the primary role carrying obligations under the CRA.
Source citations
Regulation text
Article 3(13) of Regulation (EU) 2024/2847 defines a manufacturer as:
"a natural or legal person who develops or manufactures products with digital elements or has products with digital elements designed, developed or manufactured, and markets them under its name or trademark, whether for payment, monetisation or free of charge".
Key points
- A company that commissions a product to be made by a third party, but sells it under its own brand, is the manufacturer
- The definition covers free-of-charge products — if you market it under your name, you are the manufacturer regardless of whether you charge
- Manufacturers bear the heaviest obligation burden under the CRA, including risk assessment, technical documentation, EU DoC, CE marking, vulnerability handling, and reporting (Arts. 13 & 14)
- Non-EU manufacturers supplying the EU market are still manufacturers and must comply with the CRA — they may appoint an authorised representative (Art. 18) or rely on an EU-established importer
Reclassification rule
An importer or distributor who places a product under their own name/trademark, or who carries out a substantial modification, is treated as the manufacturer (Arts. 21 & 22).