Regulation (EU) 2024/2847 · Chapter

Article 21 — Cases in which obligations of manufacturers apply to importers and distributors

When manufacturer duties travel: rebranding and substantial modification downstream.

LAW Official text — verbatim from the Official Journal snapshot; only the Official Journal is authentic.

An importer or distributor shall be considered to be a manufacturer for the purposes of this Regulation and shall be subject to Articles 13 and 14, where that importer or distributor places a product with digital elements on the market under its name or trademark or carries out a substantial modification of a product with digital elements already placed on the market.

BINDING Source: Regulation (EU) 2024/2847 (Cyber Resilience Act) · publisher European Union · captured 2026-09-16 · snapshot sha256:27b7c6c64c773001… · CELEX 32024R2847

What this article does

Article 21 is the anti-loophole article: an importer or distributor is considered a manufacturer — carrying the manufacturer's full duty set — when it markets a product under its own name or trademark, or substantially modifies a product already placed on the market F-106 F-014.

The two triggers

Rebranding is the visible one: your name on the box, your name on the duty set F-106. Modification is the quieter one: a downstream actor whose changes affect essential-requirements compliance or the intended purpose has created, in effect, a new product to answer for F-014.

Why the supply chain should care

The comfortable checklists of the importer and distributor roles F-012 F-013 are conditional on staying inside those roles. Article 21 is where the condition is written down.

Verified facts this page relies on

F-106 Marketing a product under your own name or trademark makes you the manufacturer even if someone else developed it. Art. 3(13), Art. 21
F-014 Substantial modification: a change after placing on the market affecting compliance with essential requirements or resulting in a modification of the intended purpose; a person who substantially modifies a product becomes its manufacturer. Art. 3(30), Art. 22
F-012 Importers place only compliant products on the market; verify conformity assessment, technical documentation, CE marking and manufacturer identification; indicate their own name and address; report known vulnerabilities to the manufacturer; keep the declaration of conformity; cooperate with authorities. Art. 19
F-013 Distributors act with due care; verify CE marking, declaration of conformity and manufacturer/importer obligations; do not make non-compliant products available; report vulnerabilities to the manufacturer; cooperate with authorities. Art. 20

Facts are maintained and human-verified in the CEMarque Facts Table (v2026.09.4, verified 2026-09-10).

Editorial review: Claude (AI reviewer, delegated by the editor), 2026-10-08. Methodology and correction process: how this site works.

Related in the reference

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