Placing on the market
The first making available of a product with digital elements on the EU market. A manufacturer places a product on the market when they supply it for the first time to a distributor, importer, or user in the EU, in the course of a commercial activity, whether for payment or free of charge. The date of first market placement determines when CRA obligations take effect for that product.
Source citations
Regulation text
Article 3(21) of Regulation (EU) 2024/2847 defines placing on the market as:
"the first making available of a product with digital elements on the Union market".
Relationship with making available
Placing on the market is a subset of making available — it is specifically the first instance of making a particular product available on the EU market.
Crucially, the 2022 Blue Guide (§2.3) clarifies that placing on the market refers to each individual product (each unit), not to a product type or model. Every unit of a given model has its own placing-on-the-market event, occurring when that specific unit is first supplied to a distributor, importer, or user in the EU. Subsequent supply of that same unit further down the chain is "making available" but not a new "placing on the market".
This distinction matters for transitional provisions: when new EU harmonisation requirements enter into force, individual units placed on the market on or after the application date must comply with the new requirements — even if other units of the same model were placed on the market before the deadline.
Commercial activity requirement
The CRA applies to placing on the market "in the course of a commercial activity". The regulation's recitals make clear that this includes:
- Products offered for monetary payment
- Free-of-charge products offered for monetisation (e.g., advertising-funded)
- Products where the manufacturer collects data that they use commercially
- Free-of-charge software where the manufacturer has a commercial model linked to the software
Purely gratuitous, non-commercial development (e.g. a hobbyist releasing software free of any commercial intent) is outside the scope.
When does the obligation clock start?
The manufacturer must have:
- Completed the conformity assessment and affixed CE marking
- Drawn up and signed the EU DoC
- Compiled the technical documentation
...all before first placing the product on the market. There is no grace period after market placement.
Application date
From 11 December 2027, products placed on the EU market must comply with the CRA (Art. 71(2)). Per the Blue Guide per-unit rule above (confirmed by CRA Commission FAQ Q7.2), each individual unit first supplied to a distributor, importer, or user on or after that date must comply — regardless of whether other units of the same model were placed on the market earlier. Units already in the distribution chain before 11 December 2027 may continue to circulate ("make available") without full CRA compliance under Art. 69(2) (the grandfathering rule).
Vulnerability and incident reporting obligations (Art. 14) apply from 11 September 2026 under Art. 69(3) and cover all manufacturers, including those whose products benefit from the Art. 69(2) grandfathering rule.