Article 6 applies to importers — companies that bring products from non-EU manufacturers into the EU market. If you sell products manufactured outside the EU under your own brand or distribution model, Article 6 makes you responsible for verifying CRA compliance and potentially stepping into the manufacturer's obligations if the original manufacturer is unreachable.
Who Is an Importer Under the CRA?
An importer is any natural or legal person established in the EU who places a product from a non-EU manufacturer on the EU market.
- A UK-based manufacturer selling into the EU after Brexit
- An EU distributor that rebrands products from Chinese or US manufacturers
- An EU-based company that uses a contract manufacturer in Asia
If you place a non-EU manufacturer's product on the EU market — even if you do not physically import goods — you may have importer obligations under the CRA.
What Importers Must Verify
Before placing a product on the EU market, importers must verify that the manufacturer has:
- Carried out the appropriate conformity assessment procedure
- Drawn up the technical documentation
- Affixed the CE marking correctly
- Provided the EU Declaration of Conformity
- Complied with Article 13 (CVD policy) and Article 10 (product security requirements)
Importers cannot simply take manufacturers at their word — they must conduct reasonable due diligence checks, particularly for Annex III products.
When Importers Become Responsible as Manufacturers
In certain circumstances, an importer takes on manufacturer-level obligations:
- Non-compliant products: If an importer knows or has reason to believe a product does not comply with the CRA but places it on the market anyway, they bear joint liability.
- Unreachable manufacturer: If the manufacturer is established outside the EU and cannot be contacted by market surveillance authorities, the importer steps into the manufacturer's role.
- Own-brand products: If an importer places products on the market under their own brand name (white-labelling), they are treated as the manufacturer.
This last point is particularly significant for companies that source hardware from ODMs and sell under their own brand.
CVD Portal helps you comply with Article 6 automatically.
Public submission portal, 48-hour acknowledgment tracking, Article 14 deadline alerts, and CSAF advisory generation. Free forever.
Start your free portalFrequently asked
Does the CRA apply to UK companies selling into the EU?+
Yes. UK companies that sell products to EU customers are subject to the CRA regardless of Brexit. If the UK company has no EU establishment, an EU-based importer or authorised representative is required for CRA compliance purposes.
What is an 'EU authorised representative' under the CRA?+
Non-EU manufacturers must designate an EU authorised representative — an entity established in the EU that acts as the legal contact point for market surveillance authorities. The authorised representative holds copies of the DoC and technical file and can be contacted if the manufacturer is unreachable.
Need a CVD policy that satisfies Article 6?
Download a free CRA-compliant template and deploy it in minutes.