CRA traceability is designed to let market surveillance authorities follow products through the economic-operator chain. Importers and distributors should therefore preserve product, supplier and downstream business records in a way that can be retrieved by product or shipment rather than relying only on general accounting history.
Article 23 Applies Across Economic Operators
The traceability duty applies to economic operators, including manufacturers, importers and distributors. It supports authority visibility across the supply chain rather than focusing only on one market-access role.
Record Who Supplied the Product
On request, the operator must be able to provide the name and address of the economic operator that supplied it with the product. Product records should therefore connect received goods to the actual upstream legal entity.
Record Downstream Economic Operators Where Available
Article 23 also requires, where available, the name and address of economic operators to whom the product was supplied. This is not framed as universal end-user tracking but as economic-operator chain traceability.
Retain Records for 10 Years
The required information must be presentable for 10 years after the operator was supplied with the product and for 10 years after it supplied the product. Retention systems should therefore outlast ordinary short-term order workflows.
Make Records Product-Specific
General supplier and customer directories are not enough if they cannot show which product or shipment came from or went to which economic operator. Use product identifiers, order records, batch or version information where available.
Connect Traceability to Corrective Action
Good traceability makes withdrawal, recall and targeted security communication more effective because operators can identify affected supply paths and downstream recipients.
Prepare for Reasoned Authority Requests
Records should be retrievable in a form that can be provided to market surveillance authorities without reconstructing years of supply history manually.
Keep Role Information With the Traceability Record
Where a company acts as importer for one product and distributor for another, record the role performed for each supply path. This helps connect traceability to the correct CRA obligations.
Official sources
Read the full legal text and Commission material for precise wording, qualifications and updates.