Placing on the market
The first making available of a product with digital elements on the EU market. A manufacturer places a product on the market when they supply it for the first time to a distributor, importer, or user in the EU, in the course of a commercial activity, whether for payment or free of charge. The date of first market placement determines when CRA obligations take effect for that product.
Source citations
Regulation text
Article 3(21) of Regulation (EU) 2024/2847 defines placing on the market as:
"the first making available of a product with digital elements on the Union market".
Relationship with making available
Placing on the market is a subset of making available — it is specifically the first instance of making a product available. Every subsequent supply of that product (or identical products of the same model) is "making available on the market" but not "placing on the market".
Commercial activity requirement
The CRA applies to placing on the market "in the course of a commercial activity". The regulation's recitals make clear that this includes:
- Products offered for monetary payment
- Free-of-charge products offered for monetisation (e.g., advertising-funded)
- Products where the manufacturer collects data that they use commercially
- Free-of-charge software where the manufacturer has a commercial model linked to the software
Purely gratuitous, non-commercial development (e.g. a hobbyist releasing software free of any commercial intent) is outside the scope.
When does the obligation clock start?
The manufacturer must have:
- Completed the conformity assessment and affixed CE marking
- Drawn up and signed the EU DoC
- Compiled the technical documentation
...all before first placing the product on the market. There is no grace period after market placement.
Application date
From 11 December 2027, new products placed on the EU market must comply with the CRA (Art. 71(1)). Vulnerability reporting obligations (Art. 14) apply from 11 September 2026.