Your sales page calls it one platform. Engineering sees a device, firmware and a cloud service. Which of those are you assessing under the CRA? Start by describing what the customer actually receives and what it needs to work. Otherwise a confident yes or no can refer to the wrong product.
Finish this job
Leave with a recorded product-scope decision
- 1Define the product as it is supplied.
- 2Record the market route and operator role.
- 3Preserve the conclusion and its supporting facts.
Define the product being supplied
A team may talk about one platform while customers receive a device, a software application, a remote data-processing service tied to that product or a separately supplied component. Write down the actual product boundary before answering the scope question.
Record the product name, release or version, how it is supplied and any connected service needed for it to perform one of its functions.
For example, consider a connected controller whose remote processing is developed under its manufacturer’s responsibility and is necessary for one of the controller’s functions. That service belongs in the product-boundary review. An unrelated hosted service sold by the same company is not automatically part of that product. Apply the remote-data-processing definition to the actual dependency.
Check the connection and the exclusions before concluding
Article 2(1) requires a direct or indirect data connection to a device or network in the intended purpose or reasonably foreseeable use. “It does not connect to the internet” is not enough to conclude that it falls outside the CRA.
Then check the applicable exclusions and any delegated measures. Article 2 covers, among other things, specified medical-device and vehicle legislation, certain aviation and marine equipment, identical replacement parts and products exclusively developed or modified for national security or defence. A sector label alone does not establish an exclusion; record the provision and facts you rely on.
For free and open-source software, examine the commercial-activity facts rather than treating the licence or zero price as the answer. Where the boundary or exclusion remains uncertain, record the open question and send it for review before making a product claim.
Sources: Regulation (EU) 2024/2847 — official text·European Commission — summary of the CRA
Map the EU market route
The CRA applies broadly to hardware and software products with digital elements made available on the Union market, including components placed on the market separately. The route matters because it helps establish the manufacturer, importer or distributor involved.
Use the commercial facts for the release being assessed. A general company description will not show who performs which role for this product.
Keep the evidence beside the conclusion
A reviewable scope record should retain:
- Product descriptions and release identifiers.
- The commercial route into the EU market.
- The manufacturer, importer or distributor involved.
- The role of connected services and separately supplied components.
- The source and version of the interpretation used.
Start a new assessment when the facts change
A product can change along with its connected services, market route or release model. Preserve the earlier scope decision and start a new assessment when a material fact changes.
That keeps the earlier release understandable and gives the new release its own current conclusion. A scope decision also does not mean every CRA obligation starts on the same date: Article 14 reporting applies from 11 September 2026, while the main application date is 11 December 2027.
Put the guidance into practice
Compare specific facts, worked assessment results and evidence to retain.
This article explains an operational approach to CRA preparation. It does not replace the Regulation, official guidance or advice for a specific product and organisation.
Not lawyer-reviewed.