A maker with no main EU site cannot pick a CRA report route by choice. Article 14(7) gives an order based on facts the maker has.
First, use the State where the approved agent for the most products is based. If that does not settle the route, use the importer for the most products. Next, use the seller for the most products. The last choice is the State with the most users.
Resolve each rung with evidence
Build a short route sheet before an event. For each step, state if the right party exists and which products it covers. Add the count or other check, date, and data source. Move to the next step only if the first one does not name a State.
Deals alone may not show current product scope. Compare them with live agent rights, importer records, sales data, and market proof. Mark an estimate as such. Name the person who approved the result.
Resolve ties and missing data explicitly
Before each count, define the product set and count date. State how you treat old, pulled, or repeat records. If two parties tie or proof cannot rank them, record the clash and raise it. Do not choose the party with the easiest contact.
Keep legal entity names apart from brand and group names. Link each agent, importer, or seller to the products in its source record. A group deal is not product proof by itself.
Preserve the selected route
Keep the result by the report steps. Add the main CSIRT contact and check date. Review it after a change in agent, seller, products, or EU user spread. An old route note can waste time while the 24-hour clock runs.
The last step may set the first route based on user place. If so, Article 14(7) allows later notices to use the same main CSIRT. Record that choice. A later team should not reopen it for no reason.
Save the sheet used for each filed stage. A later change in products or users may alter future routes. It does not change the proof for an old notice. Record the dates and reviewer for each sheet.
Hand a route packet to the reporter
The pack should name the legal maker and prove no main EU site sets the route. Show each step tested, its proof, the chosen State, and main CSIRT. Add the choice owner and review date. The filing person should not infer the step from a contact list.
Run a drill with one missing agent record and one importer count in dispute. The team should keep the doubt and report clock clear. It should raise the legal route choice without making up data.
Keep legal and portal roles distinct
The party that helps use the report site does not always set the legal route. Record who owns the Article 14 choice and who may file. Link the proof for the chosen State.
This guide covers the route only. It does not decide if a product or event is in scope. It is not legal advice.
Continue this workflow with the non-EU manufacturer scope record and the coordinating-CSIRT analysis.