Are distributors required to bring into compliance products with digital elements placed on the market before 11 December 2027?
No, products with digital elements placed on the market before 11 December 2027 are not subject to the requirements of the CRA (with the exception of reporting obligations), unless they are substantially modified. Distributors are therefore not required to bring such products into compliance with the CRA on or after 11 December 2027, unless they carry out a substantial modification.
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.