Do common consulting arrangements make me a manufacturer?

No, common consulting arrangements do not make you a manufacturer under the CRA. If you are a consultant providing services (such as helping a client install, configure, or integrate software), you are providing a service, not placing a product on the market.

However, there is an important exception: if you provide consulting services around an open source project that you publish and monetise (for example, selling implementation or integration services for your own software), this commercial activity may mean you are placing that software on the market. In that case, you would have manufacturer obligations toward your clients for that project.

Note that these manufacturer obligations would apply only to the monetised version of your software. For a non-monetised version of the same open source project, you would have steward obligations if you are an organisation (a legal person, see What is a legal person ?) that provides sustained support for its development. If you are an individual (a natural person), the non-monetised version falls outside the scope of the CRA entirely.