Obligations library

Every obligation under Regulation (EU) 2024/2847 — traceable to the article, with plain-language explanations and evidence guidance.

OBL-ART6-01Binding

Ensure the product meets essential cybersecurity requirements (Annex I Part I)

Products with digital elements may be placed on the EU market only where they meet the essential cybersecurity requirements set out in Part I of Annex I, provided they are properly installed, maintained, and used for their intended purpose, and where applicable, the necessary security updates have been installed.

Art. 6(a)
Manufacturer
OBL-ART6-02Binding

Ensure vulnerability handling processes meet essential requirements (Annex I Part II)

Products with digital elements may be placed on the EU market only where the processes put in place by the manufacturer comply with the essential cybersecurity requirements set out in Part II of Annex I, covering how the manufacturer identifies, handles, and discloses vulnerabilities throughout the support period.

Art. 6(b)
Manufacturer
OBL-ART7-01Binding

Determine whether your product is an "important product" and apply the correct conformity assessment

Products whose core functionality falls within a category listed in Annex III are "important products with digital elements" and must undergo a more stringent conformity assessment procedure than default products. Class I important products may use Module A self-assessment only if harmonised standards or common specifications are applied; otherwise a notified body is required. Class II always requires a notified body.

Art. 7(1)Art. 7(2)Art. 32
Manufacturer
OBL-ART8-01Binding

Determine whether your product is a "critical product" and obtain European cybersecurity certification

Products whose core functionality falls within Annex IV (hardware security boxes, smart meter gateways, and smartcards/secure elements) are "critical products with digital elements". Once the Commission adopts the relevant delegated act, they must obtain a European cybersecurity certificate at assurance level 'substantial' or higher under a relevant EUCC scheme. Until that delegated act applies, Module B+C or Module H conformity assessment is required.

Art. 8(1)Art. 32(4)
Manufacturer
OBL-ART13-01Binding

Ensure product security throughout its lifecycle (secure by design)

Manufacturers must design, develop, and produce products with digital elements so that they provide an appropriate level of cybersecurity based on the risks. Security must be addressed throughout the product's lifecycle — from design through decommissioning.

Art. 13(1)Art. 13(2)
Manufacturer
OBL-ART13-02Binding

Conduct a cybersecurity risk assessment before placing on the market

Before placing a product with digital elements on the market, manufacturers must carry out an assessment of the cybersecurity risks associated with the product. The risk assessment must inform the product's design, development, and production, and must be documented as part of the technical file.

Art. 13(2)
Manufacturer
OBL-ART13-03Binding

Draw up and maintain technical documentation (Annex VII)

Manufacturers must draw up technical documentation containing all information necessary to demonstrate that the product conforms to the CRA essential requirements. The documentation must be kept up to date and retained for ten years from placing on the market (or the product's expected lifetime if longer).

Art. 13(3)Art. 13(13)
Manufacturer
OBL-ART13-04Binding

Undergo the applicable conformity assessment procedure

Manufacturers must demonstrate conformity using the procedure appropriate to their product class. Default products may self-certify (Module A). Important Class I products may self-certify if harmonised standards are applied; otherwise a notified body must be involved. Important Class II and Critical products always require a notified body.

Art. 13(4)Art. 32
Manufacturer
OBL-ART13-05Binding

Exercise due diligence over software components (SBOM and supply chain)

Where a software component incorporated in a product with digital elements is not developed by the manufacturer, the manufacturer must exercise appropriate due diligence to ensure that the component does not compromise the product's security. A software bill of materials (SBOM) must be prepared and maintained as part of the technical documentation.

Art. 13(5)
Manufacturer
OBL-ART13-06Binding

Ensure no known exploitable vulnerabilities when placing on the market

When placing a product with digital elements on the market, manufacturers must ensure the product does not contain any known exploitable vulnerabilities. This obligation applies at the time of distribution and to each subsequent update that is released.

Art. 13(6)
Manufacturer
OBL-ART13-07Binding

Establish and publish a coordinated vulnerability disclosure (CVD) policy

Manufacturers must put in place a policy for coordinated vulnerability disclosure (CVD) and make it publicly accessible. The policy must provide a contact point for reporting vulnerabilities and describe how the manufacturer will handle reports, including acknowledgement timelines and the process for coordinating disclosure with researchers.

Art. 13(7)
Manufacturer
OBL-ART13-08Binding

Declare and disclose the product support period

Manufacturers must declare the support period for their product and make that information available to users before purchase. The support period must be at least five years, unless the expected use period of the product is shorter. The support-period end date must appear in product documentation and at the point of sale.

Art. 13(8)
Manufacturer
OBL-ART13-09Binding

Provide security updates throughout the support period

Manufacturers must provide security updates free of charge for at least five years (or the expected use period if shorter). Updates must be delivered promptly, separately from functionality updates, and the support-period end date must be disclosed.

Art. 13(9)Art. 13(8)
Manufacturer
OBL-ART13-10Binding

Handle and remediate vulnerabilities throughout the support period

Manufacturers must have processes to identify, analyse, and address vulnerabilities in their products throughout the entire support period. Annex I Part II specifies detailed requirements including CVE assignment, CVSS scoring, coordinated disclosure, and timely remediation.

Art. 13(10)
Manufacturer
OBL-ART13-11Binding

Draw up an EU Declaration of Conformity (EU DoC)

Manufacturers must draw up an EU Declaration of Conformity in accordance with Article 28 and Annex V, stating that the product meets all applicable CRA requirements. The EU DoC must be kept up to date and made available to market surveillance authorities and, where applicable, to users.

Art. 13(11)Art. 28
Manufacturer
OBL-ART13-12Binding

Affix the CE marking to the product

Manufacturers must affix the CE marking to their products before placing them on the EU market, as evidence that the product conforms to all applicable CRA requirements. The CE marking must be visible, legible, and indelible, and must not be affixed before the EU Declaration of Conformity is drawn up.

Art. 13(12)Art. 30
Manufacturer
OBL-ART13-13Binding

Ensure product can be uniquely identified (serialisation)

Manufacturers must ensure that each product with digital elements bears a type, batch number, serial number, or other element that allows its identification. For software-only products, the version number serves this purpose.

Art. 13(14)
Manufacturer
OBL-ART13-14Binding

Mark the product with manufacturer contact information

Manufacturers must indicate their name, registered trade name or trademark, and postal address on the product or its packaging. An electronic contact address (website or email) must also be indicated where available. This enables market surveillance authorities, importers, distributors, and users to contact the manufacturer.

Art. 13(15)
Manufacturer
OBL-ART13-15Binding

Provide instructions and information to users (Annex II)

Manufacturers must accompany the product with the information and instructions listed in Annex II, in a language easily understood by users. This includes the product identity, security capabilities, contact for reporting vulnerabilities, the support period end date, and guidance on secure use.

Art. 13(16)
Manufacturer
OBL-ART13-16Binding

Take corrective measures and cooperate with market surveillance

Where a manufacturer has reason to consider that a product placed on the market does not conform with CRA requirements, they must immediately take corrective measures — including withdrawal or recall if necessary. Manufacturers must also cooperate with market surveillance authorities and provide all requested information and documentation.

Art. 13(17)Art. 13(18)
Manufacturer
OBL-ART14-01Binding

Report actively exploited vulnerabilities and incidents to ENISA

Manufacturers must report any actively exploited vulnerability in their product to ENISA via the single reporting platform within 24 hours (early warning) and 72 hours (notification). A final report is due within 14 days. This obligation applies from 11 September 2026.

Art. 14(1)Art. 14(2)Art. 14(3)
Manufacturer
OBL-ART14-02Binding

Submit a detailed vulnerability notification to ENISA within 72 hours

Within 72 hours of becoming aware of an actively exploited vulnerability in a product, manufacturers must submit a detailed vulnerability notification to ENISA via the single reporting platform. This follows the 24-hour early warning (OBL-ART14-01) and must include technical details about the vulnerability and the product affected.

Art. 14(2)Art. 14(5)
Manufacturer
OBL-ART14-03Binding

Submit a final vulnerability report to ENISA within 14 days

Within 14 days of becoming aware of an actively exploited vulnerability, manufacturers must submit a final report to ENISA containing a complete description of the vulnerability, the corrective measures taken, and whether the vulnerability has been publicly disclosed or a CVE has been assigned.

Art. 14(3)Art. 14(5)
Manufacturer
OBL-ART14-04Binding

Notify users of actively exploited vulnerabilities without undue delay

When a vulnerability is actively exploited, manufacturers must notify affected users without undue delay. The notification must include information sufficient for users to take protective action, including mitigating measures available before a patch is released.

Art. 14(4)
Manufacturer
OBL-ART18-01Binding

Ensure any authorised representative mandate covers the minimum statutory tasks

A manufacturer may appoint an authorised representative (AR) by written mandate. The mandate must allow the AR to perform at least three minimum statutory tasks: keeping the EU DoC and technical documentation available to market surveillance for at least 10 years or the support period; providing conformity information on request; and cooperating with market surveillance on corrective measures. Core design and production obligations cannot be delegated to the AR.

Art. 18(1)Art. 18(2)Art. 18(3)
Manufacturer
OBL-ART19-01Binding

Verify product conformity before placing on the EU market

Before placing a product with digital elements on the EU market, importers must verify that the manufacturer has carried out the appropriate conformity assessment, drawn up technical documentation, affixed the CE marking, and made the EU declaration of conformity or declaration of performance available.

Art. 19(1)
Importer
OBL-ART19-02Binding

Do not place non-conforming products on the market

Where an importer considers or has reason to believe that a product with digital elements is not in conformity with the essential cybersecurity requirements, the importer must not place the product on the market until conformity is achieved.

Art. 19(2)
Importer
OBL-ART19-03Binding

Label products with importer contact details

Importers must indicate their name, registered trade name or trademark, postal address, and where available their website or email address, on the product itself, on its packaging, or in a document accompanying the product.

Art. 19(3)
Importer
OBL-ART19-04Binding

Ensure safe storage and transport conditions

While a product with digital elements is under the importer's responsibility, the importer must ensure that storage and transport conditions do not jeopardise its conformity with the essential cybersecurity requirements.

Art. 19(4)
Importer
OBL-ART19-05Binding

Take corrective action and report significant cybersecurity risks

If an importer learns that a product they have placed on the market is not in conformity, they must immediately take corrective action — including withdrawal or recall if necessary. Where the product poses a significant cybersecurity risk, the importer must immediately notify the relevant national competent authority.

Art. 19(5)
Importer
OBL-ART19-06Binding

Retain documentation for 10 years

Importers must keep a copy of the EU declaration of conformity or declaration of performance for 10 years after the product is placed on the market, and ensure that technical documentation can be made available to market surveillance authorities upon request.

Art. 19(6)
Importer
OBL-ART19-07Binding

Cooperate with market surveillance authorities

Upon a reasoned request from a competent authority, importers must provide all information and documentation — in paper or electronic form — necessary to demonstrate the conformity of a product with digital elements. They must also cooperate on any corrective action required.

Art. 19(7)
Importer
OBL-ART20-01Binding

Verify product conformity before making available on the market

When making a product with digital elements available on the market, distributors must act with due care and verify that the product bears the CE marking, is accompanied by the required documentation and information, and that the manufacturer and importer (if applicable) have complied with their labelling and identification obligations.

Art. 20(1)
Distributor
OBL-ART20-02Binding

Do not make non-conforming products available on the market

Where a distributor considers or has reason to believe that a product is not in conformity with the CRA's essential requirements, the distributor must not make the product available on the market until conformity is achieved, and must notify the manufacturer and, where applicable, the market surveillance authority.

Art. 20(2)
Distributor
OBL-ART20-03Binding

Ensure safe storage and transport conditions

Distributors must ensure that, while a product with digital elements is under their responsibility, storage and transport conditions do not jeopardise its conformity with the essential cybersecurity requirements.

Art. 20(3)
Distributor
OBL-ART20-04Binding

Take corrective action and report significant cybersecurity risks

If a distributor learns that a product they have made available on the market is not in conformity, they must immediately take corrective action including withdrawal or recall if necessary. Where the product poses a significant cybersecurity risk, they must immediately notify the relevant national market surveillance authority.

Art. 20(4)
Distributor
OBL-ART20-05Binding

Cooperate with market surveillance authorities

Upon a reasoned request from a competent authority, distributors must provide all information and documentation necessary to demonstrate the conformity of a product, and cooperate on any corrective action required by that authority.

Art. 20(5)
Distributor
OBL-ART22-01Binding

Any person making a substantial modification and placing the product on the market becomes a manufacturer

Any natural or legal person — other than the original manufacturer, importer, or distributor — who carries out a substantial modification of a product and then makes it available on the market is treated as the manufacturer. That person is then subject to Articles 13 and 14 either for the affected part of the product or, if the modification affects the entire product's cybersecurity, for the whole product.

Art. 22(1)Art. 22(2)Art. 13+1 more
ManufacturerImporterDistributor
OBL-ART23-01Binding

Maintain supply chain traceability records and provide them on request

All economic operators must be able to identify, on request from market surveillance authorities, (a) any economic operator who supplied them with a product, and (b) any economic operator to whom they supplied a product. Records must be maintainable for 10 years from each transaction.

Art. 23(1)Art. 23(2)
ManufacturerImporterDistributorOpen-source steward
OBL-ART24-01Binding

Establish and document a cybersecurity policy for open-source software

Open-source software stewards must put in place and document a cybersecurity policy that fosters the development of a secure product and enables effective handling of vulnerabilities in the open-source software components they support.

Art. 24(1)
Open-source steward
OBL-ART24-02Binding

Notify actively exploited vulnerabilities and severe incidents

Open-source software stewards must notify the relevant CSIRT (computer security incident response team) designated as coordinator without undue delay of any actively exploited vulnerability contained in their open-source software components, as well as any severe incident affecting the security of those components.

Art. 24(2)
Open-source steward
OBL-ART24-03Binding

Cooperate with market surveillance authorities

Open-source software stewards must cooperate with market surveillance authorities upon request and provide all information required for the performance of their regulatory tasks.

Art. 24(3)
Open-source steward
OBL-ART24-04Binding

Draw up technical documentation on request

Upon request from market surveillance authorities, open-source software stewards must draw up and keep up-to-date technical documentation for the open-source software components they administer, sufficient to allow assessment of cybersecurity compliance.

Art. 24(4)
Open-source steward
OBL-ART28-01Binding

Draw up an EU Declaration of Conformity containing all required information

Manufacturers must draw up an EU Declaration of Conformity (EU DoC) that follows the Annex V model structure and contains all specified elements. The EU DoC states that the product meets the applicable essential cybersecurity requirements. A simplified version (Annex VI) may accompany the product provided the full DoC is accessible online. The DoC must be updated whenever relevant changes occur.

Art. 28Art. 13(12)Art. 13(20)
Manufacturer
OBL-ART31-01Binding

Draw up and maintain technical documentation containing all Annex VII elements

Manufacturers must draw up technical documentation before placing a product on the market, and continuously update it (at least during the support period). The documentation must contain all elements listed in Annex VII, demonstrating how the product and the manufacturer's processes comply with the essential cybersecurity requirements in Annex I. It must be kept available to market surveillance authorities for at least 10 years or the support period.

Art. 31Art. 13(12)Art. 13(13)
Manufacturer
OBL-ART32-01Binding

Select and complete the correct conformity assessment procedure before placing the product on the market

Manufacturers must perform a conformity assessment demonstrating that both the product and the manufacturer's processes meet the Annex I essential requirements, before placing the product on the market. The required procedure depends on the product's classification: Module A self-assessment for default products, third-party assessment for important products in certain circumstances, and mandatory notified-body involvement for Class II important and critical products.

Art. 32(1)Art. 32(2)Art. 32(3)+1 more
Manufacturer
Obligations library — CRA Compliance Hub