Are manufacturers required to ensure the conformity of “existing” product types?
The CRA is applicable to products placed as individual units on the market as of its date of applicability. In other words, legacy types or models are not exempted from the application of the CRA if, after the aforementioned date, new units are placed on the market. The CRA provides a transition period between its entry into force (10 December 2024) and its date of application (11 December 2027 for the majority of the obligations) to ensure a smooth implementation. During this period, the manufacturer has to adapt the product to the CRA requirements, if needed, and perform the conformity assessment described in this chapter.
Module H might be helpful for manufacturers of important and critical products that place numerous types or models on the market since it provides a holistic system that streamlines the conformity assessment.
Disclaimer
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.