Topic
Products already on the market
What the 2027 line actually grandfathers, and what it does not.
Products placed on the market before 11 December 2027 owe conformity only if substantially modified after that date F-004. Two live edges: the reporting duty applies from 11 September 2026 regardless F-002 F-004, and any substantial modification — a compliance-affecting change or a repurposing — brings the product under the full duty set F-004 F-014.
The strategic reading
Grandfathering defers the conformity duty but not the commercial question: customers and distributors may ask about conformity regardless of the legal minimum, so treat the date as a scheduling input F-105.
Verified facts this page relies on
- 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)
- F-002 Article 14 (reporting obligations of manufacturers) applies from 11 September 2026. Art. 71(2)
- F-105 For products already on the market, conformity is not required until substantial modification, but customers and distributors may ask for it; Article 14 applies regardless. Art. 69(2)–(3)
- 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
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.