Are You a Manufacturer Under the CRA? Your Role as a Software Developer

Alright, listen up. You're coding away, building that next big app, game, or software library. But when does the EU Cyber Resilience Act (CRA) officially see you as a 'manufacturer'? It's simpler than you might think.

If you develop software, or have it designed and developed, and then you put it on the EU market under your name or trademark – whether you charge for it, monetize it through other services, or even offer it for "free" but it's part of a commercial activity – you're likely a manufacturer in the eyes of the CRA (Article 3(13) of the CRA legal text). This isn't just for massive corporations; solo developers and indie studios fall under this too if your software is supplied for distribution or use on the Union market in the course of a commercial activity (Recital 15 of the CRA legal text).

Understanding this is crucial because being classified as a manufacturer means you have a set of direct responsibilities under the CRA. Get this straight from the start.

Key Takeaway

If you commercially develop and market software in the EU under your brand, the CRA views you as a manufacturer, and you're on the hook for its compliance.