CRA · IMPORTER

CRA obligations for importers

You're an importer under the CRA if you place a product with digital elements from a manufacturer established outside the EU onto the EU market. That carries real verification and record-keeping duties — the ones generic ISMS toolkits, built for manufacturers, simply don't cover.

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

What the CRA asks of importers

Chapter II, Article 19 — obligations of importers.

  1. Verify
    Place only conforming products

    Before you place a product with digital elements on the EU market, satisfy yourself that the manufacturer carried out the conformity assessment, drew up the technical documentation, affixed the CE marking, and provided the EU Declaration of Conformity and user information.

  2. Identify
    Put your identity on it

    Indicate your name, registered trade name or trademark and a contact address on the product — or, where that's not possible, on its packaging or in a document accompanying it.

  3. 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.

  4. Act on doubt
    Withhold, inform, cooperate

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

  5. Records
    Keep the evidence available

    Keep a copy of the EU Declaration of Conformity and ensure the technical documentation can be made available to authorities on request, throughout the support period and the retention window.

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 an importer, 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 Importer pack

CRA Importer pack · 6 documents
  • Importer obligations summary
  • Pre-market due-diligence checklist
  • Conformity verification record
  • Article 14 awareness note
  • Records & retention 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.