The checklist should operate as a release gate rather than a document folder. Every item needs an owner, evidence reference, status and escalation path so that missing or inconsistent CRA information stops market placement before products reach the Union market.
1. Confirm the Product and CRA Scope
Identify the exact product, model, version and intended purpose and confirm that the CRA applies. Market-access evidence should be product specific rather than based on a general supplier statement.
2. Identify the Legal Manufacturer
Record the non-EU legal entity that meets the CRA manufacturer definition and confirm that its identity matches product and conformity documentation.
3. Identify the EU Importer
Record the EU-established person that will place the product on the Union market and confirm that it accepts the Article 19 role and operational responsibilities.
4. Check the Conformity Assessment Route
Confirm which Article 32 conformity procedure applies and that the manufacturer has completed it. Escalate products where the route is unclear or inconsistent with classification.
5. Confirm Technical Documentation Exists
The importer must ensure that the manufacturer has drawn up technical documentation. Record where the evidence is controlled and how authority requests will be supported.
6. Verify CE Marking
Check that the product bears the required CE marking and that the marking is consistent with the product and conformity evidence.
7. Verify the EU Declaration of Conformity
Confirm that the declaration accompanies the product as required, identifies the relevant product and manufacturer and aligns with the conformity route.
8. Verify Annex II Information and Instructions
Check the required user information and instructions, including the appropriate language for the target market and required security and support information.
9. Verify Manufacturer Identification
Confirm the required manufacturer identity and contact information is present and consistent across the product, packaging and documentation.
10. Add and Verify Importer Identification
Ensure the importer provides its required name and contact information through the permitted presentation route without obscuring manufacturer information.
11. Check Support-Period Information
Confirm the support-period end date information required from the manufacturer is available and consistent with product documentation and customer-facing materials.
12. Confirm Vulnerability and Security Contacts
Ensure the importer knows how to reach the manufacturer's security contact and how internal staff should escalate vulnerabilities or significant cybersecurity risk.
13. Create Article 23 Traceability Records
Link the product to the upstream supplier and downstream economic operators where available and configure retention so the information remains presentable for the required 10-year periods.
14. Check for Article 21 Role Changes
Before private-label sale or modification, determine whether the importer or distributor will place the product under its own name or trademark or substantially modify it. If so, manufacturer obligations may apply.
15. Define the Non-Conformity Escalation
Document who can stop market placement, who contacts the manufacturer, how significant cybersecurity risk is assessed and when authorities or users must be informed.
16. Approve Market Placement
Require a named approver to confirm that all mandatory evidence is complete before the product is placed on the market. Preserve the completed checklist with the product's market-access record.
Official sources
Read the full legal text and Commission material for precise wording, qualifications and updates.