You import products with digital elements into the EU or distribute them. Even without your own development, you have obligations of your own under the Cyber Resilience Act. Complass shows you what they are and documents your checks per product.
The obligations for importers and distributors apply from 11 December 2027. For radio products, comparable obligations already apply today under the Radio Equipment Directive.
Before placing a product on the market, importers check that the manufacturer has carried out the conformity assessment, drawn up the technical documentation and affixed the CE marking Art. 19 CRAArticle 19 Cyber Resilience ActObligations of importers1. Importers shall place on the market only products with digital elements that comply with the essential cybersecurity requirements set out in Part I of Annex I and where the processes put in place by the manufacturer comply with the essential cybersecurity requirements set out in Part II of Annex I. 2. Before placing a product with digital elements on the market, importers shall ensure that: - (a) the appropriate …As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗
Importers state their name and contact address on the product or its packaging and keep the EU declaration of conformity available for at least ten years Art. 19 CRAArticle 19 Cyber Resilience ActObligations of importers1. Importers shall place on the market only products with digital elements that comply with the essential cybersecurity requirements set out in Part I of Annex I and where the processes put in place by the manufacturer comply with the essential cybersecurity requirements set out in Part II of Annex I. 2. Before placing a product with digital elements on the market, importers shall ensure that: - (a) the appropriate …As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗
Before making a product available, distributors check the CE marking, the documents and the details of the manufacturer and importer Art. 20 CRAArticle 20 Cyber Resilience ActObligations of distributors1. When making a product with digital elements available on the market, distributors shall act with due care in relation to the requirements set out in this Regulation. 2. Before making a product with digital elements available on the market, distributors shall verify that: - (a) the product with digital elements bears the CE marking; - (b) the manufacturer and the importer have complied with the obligations set out …As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗
In case of vulnerabilities or non-conformity, both inform the manufacturer and, where there is a significant risk, the market surveillance authorities
Authorised representatives. Under the CRA a manufacturer can appoint an authorised representative in the EU by written mandate, who for example keeps the declaration of conformity and the technical documentation available for market surveillance and cooperates with the authorities. Development according to the cybersecurity requirements and drawing up the technical documentation remain with the manufacturer. For medical devices an authorised representative is mandatory if the manufacturer is not established in the EU. Art. 18 CRAArticle 18 Cyber Resilience ActAuthorised representatives1. A manufacturer may, by a written mandate, appoint an authorised representative. 2. The obligations laid down in Article 13(1) to (11), Article 13(12), first subparagraph, and Article 13(14) shall not form part of the authorised representative’s mandate. 3. An authorised representative shall perform the tasks specified in the mandate received from the manufacturer. The authorised representative shall provide a …As of: 06.10.2026 · Source: EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025Open original (EUR-Lex – OJ L 2024/2847, 20.11.2024, corrigenda incorporated: OJ L 2024/90780, 5.12.2024; OJ L 2025/90555, 2.7.2025; OJ L 2025/90828, 17.10.2025) ↗Art. 11 MDRArticle 11 MDRAuthorised representative1. Where the manufacturer of a device is not established in a Member State, the device may only be placed on the Union market if the manufacturer designates a sole authorised representative. 2. The designation shall constitute the authorised representative's mandate, it shall be valid only when accepted in writing by the authorised representative and shall be effective at least for all devices of the same generic …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 19.07.2026Open original (EUR-Lex – consolidated version of 19.07.2026) ↗
When you count as the manufacturer yourself. If you place a product on the market under your own name or trademark, or modify it substantially, you take on the manufacturer’s obligations (Art. 21 and 22 CRA). This also applies if another company developed the product. Go to the page for manufacturers
General information, not legal advice. This page summarises the legal position in simplified form and does not replace an assessment of your individual case. The wording of the laws and standards is authoritative.
How Complass helps
Obligations for your role
The CRA module asks for your role and shows the obligations for importers or distributors, with tasks and evidence per product.
What you need at a minimum as an importer or distributor
The first selection covers the obligations in Complass if they apply to you. The free applicability check shows whether they do. To the applicability check
What you need at a minimum
If you are only an importer or distributor under the CRA: this selection covers the resulting obligations in Complass. It is preselected when you start a trial or order.
Portal size Start
Cyber Resilience Act (CRA): Obligations of importers (Art. 19) and distributors (Art. 20): checking conformity and CE marking, informing about vulnerabilities and risks. (Art. 19, 20 CRA (opens in a new tab))
Incident management: included
GDPR, AI Act and Whistleblower protection (HinSchG) (baseline protection): included
Price of the minimum selection
Item
Net price per month
Start S
€179
Cyber Resilience Act (CRA)
included
GDPR, AI Act and Whistleblower protection (HinSchG) (baseline protection)
included
Total
€179 net/month
With annual payment, 12 months minimum term. Monthly payment with a 15 % surcharge. All prices net plus VAT, as of 16 October 2026.
Good to know: You can also meet the obligations without Complass. Complass supports you with implementation and evidence but does not replace legal advice. Legal information
Frequently asked questions
What is the difference between an importer and a distributor?+
Importers place a product from a manufacturer outside the EU on the EU market for the first time. Distributors make available a product that has already been placed on the EU market. Importers therefore check more extensively than distributors.
When do the obligations apply?+
Like most CRA obligations, the obligations for importers and distributors apply from 11 December 2027. The manufacturers’ reporting obligations have applied since 11 September 2026. Starting early lets you choose suppliers in good time and request missing documents.
We sell products under our own brand. What changes?+
Then you count as the manufacturer under the CRA and take on its obligations, even if another company developed the product. The page for manufacturers shows what lies ahead.