Should a manufacturer ensure the assessment of conformity for a product through the procedures set out in both the CRA and the MR?
Both the CRA and the MR provide for conformity assessment procedures for relevant products with digital elements (in Article 32 of the CRA) and machinery and related products (in Article 25 of the MR) respectively.
For a product with digital elements, within the meaning of the CRA, which is also a machine or related product, within the meaning of the MR, manufacturers will need to ensure the assessment of conformity through the procedures set out individually in both the CRA and the MR. The conformity assessment procedures set out in the CRA and the MR are of such a nature that the assessment of conformity on the basis of the procedure in one instrument cannot automatically be considered as sufficient to also satisfy the procedure that is required to be followed as per the other instrument (see also Recital 53 of the CRA).
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Disclaimer: This document is prepared by the Commission services and should not be considered as representative of the European Commission’s official position. The replies to the FAQs do not extend in any way the rights and obligations deriving from applicable legislation nor introduce any additional requirement. The expressed views are not authoritative and cannot prejudge any future actions the European Commission may take, including potential positions before the Court of Justice of the European Union, which is competent to authoritatively interpret Union law.