CRA Economic Operators: A Quick Look at Importers and Distributors

You might be the developer, the 'manufacturer', but the CRA also has rules for other players in the game: 'economic operators' like importers and distributors (Article 3(12) of the CRA legal text). Why should this matter to you? Because they play a role in getting your software to EU users, and their compliance (or non-compliance) can impact you.

Importers

An 'importer' is any natural or legal person established in the Union who places a software product on the EU market that bears the name or trademark of someone established outside the Union (Article 3(16) of the CRA legal text). If you're a non-EU dev selling directly to EU users, you might also be the importer. They have specific duties to check your compliance before your product hits the market.

Distributors

A 'distributor' is anyone else in the supply chain (not the manufacturer or importer) who makes your software available on the Union market without changing its properties (Article 3(17) of the CRA legal text). This could be resellers or certain types of platforms. They too have obligations, like verifying the CE marking and necessary documentation.

Knowing their roles helps you understand the entire compliance landscape your software navigates.

Key Takeaway

Even if you're the developer, be aware that importers bringing your non-EU software into the EU, and distributors making it available, have their own CRA responsibilities that can affect your product's market access.