A maker is not outside the CRA just because it is based outside the EU. The maker rules can apply when a covered digital product is offered on the EU market. A non-EU maker in scope has the Article 14 report duties. It uses the route order in Article 14(7).

Check EU market access for each product. Do not rely on the place listed as the parent firm’s head office.

For each product, name the entity that builds it or pays another party to do so. It must sell the product under its name or mark. Link that entity to product names, versions, brands, and sales deals. If group firms have different roles, do not give ownership only to the group.

Ask legal staff to review own-brand goods, build deals, and large product changes. A party called a seller in a deal may have a different legal role under the CRA.

Build a reporting-ready entity packet

For the chosen maker, keep its legal name, home law, and proof that it owns the product. List any EU sites, approved agent, importers, sellers, and product contacts. Name the people who can make and file the Article 14 choice. A head office or market brand is a link, not a substitute for the legal entity.

Check if a deal that hands off event support also changes a legal role. Save the result and source. Work help alone does not prove that another party owns the maker’s report duty.

Prove Union-market availability

Map direct sales, software files, app stores, licences, importers, sellers, and product bundles. For each record, keep its dates and product versions. A web page that people can view is not proof that the product was supplied for sale or use in the EU.

Give each unclear sales route an owner. Do not treat it as absent. The goal is a checked market choice with proof, not the widest claim.

Link each market record to a version and time. A current EU route may not prove that an old release was offered there. An old sales route may still matter to product history. Keep the proof and its date limits.

Assign the reporting route

Once a non-EU maker is in scope, apply the CSIRT order in Article 14(7). Name who may assess and file. Make sure the product, route, and State lists agree during a case.

Review the result after a launch, brand change, new seller, firm purchase, or agent change. A world-wide policy can set the method. Each case must still show the legal maker and product proof.

During a live event, save the exact entity, market, and route records used. If a fact is in dispute, name the reviewer and next source. Keep the report clock open. The filing person should explain why the entity is in scope and how the route was chosen.

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