A manufacturer with no main establishment in the Union does not choose a CRA reporting destination by preference. Article 14(7) provides an ordered test based on the information available to the manufacturer.

First use the Member State where the authorised representative acting for the highest number of the manufacturer’s products is established. If that does not resolve the route, use the importer placing the highest number of its products on the market. Next comes the distributor making the highest number available. The final fallback is the Member State containing the highest number of users.

Resolve each rung with evidence

Build a short routing worksheet before a reportable event. For every rung, record whether a relevant party exists, the products it covers, the count or other comparison used, the measurement date, and the source of the data. Move to the next rung only when the earlier one does not determine a Member State.

Contracts alone may not show current product coverage. Reconcile them with active mandates, importer records, distribution data, and product availability evidence. Mark estimates as estimates and name the person who approved the conclusion.

Resolve ties and missing data explicitly

For each comparison, define the product set, counting date, and treatment of inactive, withdrawn, or duplicate records before calculating a result. If two parties appear equal or the evidence cannot support an ordered result, record the conflict and escalate it. Do not select the party whose contact details are easiest to find.

Keep the legal-entity names distinct from trading names and group labels. Link each authorised representative, importer, or distributor to the products actually covered by the source record. A group-wide contract should not silently become product-level evidence.

Preserve the selected route

Store the result beside the reporting runbook, along with the coordinating-CSIRT endpoint and the date it was checked. Review it after changes to representatives, channel partners, product portfolios, or EU user distribution. A stale routing memo can create delay precisely when the 24-hour window is already running.

When the final user-location fallback determines the first route, Article 14(7) permits later notifications to be sent to that same coordinating CSIRT. Record that continuity decision so a later response team does not reopen the analysis without reason.

Freeze the worksheet version used for every filed stage. A later portfolio or user-distribution change may alter future routing analysis without changing the evidence that supported the earlier notification. Record the effective period and reviewer for each version.

Hand a route packet to the reporter

The packet should contain the legal manufacturer, proof that no main Union establishment controls the route, every rung tested, supporting records, selected Member State, coordinating-CSIRT destination, decision owner, and review date. The reporter should not have to infer which fallback was used from a contact-list entry.

Run a tabletop with one missing representative record and one disputed importer count. The team should be able to preserve uncertainty, keep the reporting clock visible, and escalate the legal routing decision without inventing data.

The party that helps a manufacturer access or operate the reporting platform is not automatically the party that determines the legal routing rung. Write down who owns the Article 14 decision, who is authorised to submit, and which evidence supports the chosen Member State.

This article addresses routing only. It does not decide whether a product or occurrence is in scope, and it is not legal advice.

Continue this workflow with the non-EU manufacturer scope record and the coordinating-CSIRT analysis.