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Product scope

How to determine whether the CRA applies to your product

Define the product, market route and operator role, then preserve a scope decision that can be reviewed when the product changes.

23 August 2026 5 min read Dlovan Sharif
An animated digital product framed for a product-scope decision with a blue confirmation marker

A useful CRA scope review ends with a decision tied to a specific product and release. Product names are rarely enough. The assessment needs the commercial package, the connected services required for it to function, the route into the EU market and the organisation’s role in that route.

Finish this job

Leave with a recorded product-scope decision

The scope assessment captures the product boundary, EU market route, economic-operator role, conclusion and the exact interpretation used.
  1. 1Define the product as it is supplied.
  2. 2Record the market route and operator role.
  3. 3Preserve the conclusion and its supporting facts.
Start a product-scope assessment

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.

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.

Working guidance

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.

Written by Dlovan Sharif

Founder, CRA Operations. Primary legal sources are linked alongside the article.