Defined term
Placing on the market
Defined at Article 3(21): the first supply, and why 'first' carries so much weight.
LAW Defined in Article 3 (Art. 3(21)). The verbatim definition is in the official text of Article 3; only the Official Journal is authentic.
sha256:27b7c6c64c773001… · CELEX 32024R2847Article 3(21) defines placing on the market as the first making available of a product with digital elements on the Union market. Making available, in turn, means supply for distribution or use on the EU market in the course of a commercial activity F-101.
Why "first" matters
Much of the transitional regime keys off this moment: products placed on the market before 11 December 2027 are subject to the Regulation only if substantially modified from that date, while Article 14 applies to them regardless F-004. Placing on the market is the first making available; later supply in the course of a commercial activity is still making available F-101.
The practical question is almost always "when did this specific version first ship to the EU, and what changed since" — which is exactly the pair of questions the substantial-modification rules then pick up F-004.
Verified facts this page relies on
- F-101 Made available on the market means supply for distribution or use on the EU market in the course of a commercial activity. Art. 3(22)
- F-004 Products placed on the market before 11 December 2027 are subject to the Regulation only if substantially modified after that date; Article 14 applies to them regardless. Art. 69(2)–(3)
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.