The CRA can treat an importer or seller as the maker. This occurs if it puts a product on the market under its own name or mark. It also occurs if it makes a large change to a product already on the market. The Articles 13 and 14 duties then apply.

The same rule can apply to another party that makes a large change and offers the product. It is the maker for the part it changed. If the change affects the security of the whole product, it may be the maker for all of it.

Inventory the role-changing facts

List each product sold under a house brand or new label. Add products changed after import or joined into a new offer. For each one, record:

  • the first maker;
  • the chain of deals;
  • the brand shown to users;
  • each technical change;
  • the release owner; and
  • the entity that offers it.

A buying label does not set the legal role. Terms such as “seller,” “integrator,” and “OEM” may describe a deal. They do not settle the CRA test.

Create a role-decision file

Open a file for each event that may change the role. Name the entity, first product, and new offer. Record the brand, change, possible security effect, release date, proof, and reviewer. Test the brand and the change as two separate points.

If only one part changed, map that part and what relies on it. If the change may affect all product security, keep the design and threat review that prove the result. A launch due date must not set the role before the facts are checked.

Review modifications at the product boundary

State what changed, who had control, and which part is less secure as a result. Say if the change affects the whole product. Keep proof of design, version, setup, and release. Have legal and product security leads approve the role together.

If the role changes, prepare the entity to act as a maker. It needs a product list, trigger owner, CSIRT route, filing staff, user route, and proof store. A deal in which the first maker offers help does not replace this record.

If the role does not change, explain why the brand and change tests both fail. State what new fact would reopen the check. A later software change, own-brand choice, or wider link to the product may change the result.

Keep supplier escalation alongside reporting

The new maker may still need fast proof and fixes from the first supplier. Set a safe contact route, reply times, and rules for sharing facts before an event. Link supplier notes to the case. Keep clear who owns the Article 14 choice.

Review the role when the brand, software, bundle, or work split changes. Each market offer should have one legal maker that owns the result. Base it on product facts, not supply-chain labels.

At intake, settle the role before naming the Article 14 owner. Link supplier help and proof to the case. Keep the approved maker choice clear to each reporter and reviewer.

Continue this workflow with the manufacturer register and the non-EU manufacturer analysis.