CRA · DISTRIBUTOR

CRA obligations for distributors

You're a distributor under the CRA if you make a product with digital elements available on the EU market without being its manufacturer or importer. Your duties are lighter than the manufacturer's, but they're real — a set of checks and records most toolkits never give you.

Article 14 reporting · 11 Sep 2026 · full application 11 Dec 2027

What the CRA asks of distributors

Chapter II, Article 20 — obligations of distributors.

  1. Verify
    Check before you make it available

    Before making a product with digital elements available on the market, verify it bears the CE marking, that the manufacturer and importer have met their identification duties, and that the required user information and instructions are present.

  2. Preserve
    Don't compromise compliance

    While the product is under your responsibility, ensure storage and transport conditions don't put its compliance with the essential cybersecurity requirements at risk.

  3. Act on doubt
    Withhold, inform, cooperate

    If you believe a product is not in conformity, don't make it available until it is. Where it presents a significant cybersecurity risk, inform the manufacturer or importer and the market-surveillance authorities, and cooperate on corrective action.

  4. Cooperate
    Help demonstrate conformity

    On a reasoned request, provide the information and documentation needed to demonstrate the product's conformity, and cooperate on any action to eliminate the risks posed by products you've made available.

Article 14 reporting is the manufacturer's duty — not yours.

The 24h / 72h / 14-day incident-and-vulnerability reporting under Article 14 sits with the manufacturer. As a distributor, your job is to verify, keep records, and inform the manufacturer and authorities when something looks wrong. The pack gives you exactly those instruments.

The CRA Distributor pack

CRA Distributor pack · 5 documents
  • Distributor obligations summary
  • Due-diligence checklist
  • Non-conformity action procedure
  • Records & traceability template
  • Market-surveillance cooperation
updated 2026-07-01 · v1.4 · aligned to Reg (EU) 2024/2847

Indicative summary, not legal advice. Obligations depend on the specific product and the current text of Reg (EU) 2024/2847. Confirm with qualified counsel before relying on it.