OEM and ODM arrangements distribute engineering responsibility across multiple entities. The CRA cuts through that distribution with a single test under Art. 3(13): the manufacturer is whoever develops or has developed a product with digital elements and markets it under their name or trademark. In a pure OEM model — where the brand owner specifies the design and the factory produces to specification — the brand owner is the manufacturer. In a pure ODM model — where the factory designs and the brand owner rebrands — the brand owner is still the manufacturer because they market it under their trademark. The factory, unless it also sells the same product under its own brand, is a contract producer outside the CRA's manufacturer definition. Art. 22 adds one more trigger: a substantial modification by any party makes that party the manufacturer for the affected part of the product. CRACheck generates the 8-document Art. 31 technical file. €149 per product. 15-25 minutes. Design data stays in your browser.
€149 one-time · 8-document ZIP · 15–25 minutes · Browser-side
Art. 3(13) of Regulation (EU) 2024/2847 does not test who built the product. It tests who markets it under their name. In ODM arrangements, the factory designs and produces, but if the brand owner markets the finished product under its own trademark, the brand owner is the manufacturer. The factory is a contract producer with no CRA manufacturer obligations for that branded product.
If the factory sells the same product under its own brand AND the brand owner sells it under a different brand, both are manufacturers under Art. 3(13) — each for their own market placement. Each must produce independent Art. 31 documentation and each faces Art. 64(2) penalties independently.
Art. 22 of Regulation (EU) 2024/2847 states that any person who carries out a substantial modification and makes the product available on the market becomes the manufacturer. Customising firmware, changing security configurations, or altering the product's intended purpose can trigger this — even if the original product was CRA-compliant.
8 PDF documents generated from your data. Each cites the specific article of Regulation (EU) 2024/2847 it complies with.
Identifies the CRA category for the product as placed on the market by the manufacturer of record.
Art. 31 and Annex VII documentation produced by the manufacturer (brand owner). Engineering data sourced from the OEM/ODM factory, structured into the regulatory format.
Cybersecurity risk assessment per Art. 13(2)-(3) covering the product as marketed, including factory-provided component data.
Annex II information under the brand owner's identity, with vulnerability reporting contact and support period.
EU Declaration per Art. 28 and Annex V issued by the brand owner as manufacturer.
Coordinated vulnerability disclosure policy under the brand owner's coordination, with factory involvement documented.
ENISA notification template for the entity classified as manufacturer. Art. 14(2): early warning within 24h, notification within 72h, final report within 14 days.
Key dates accounting for OEM/ODM contract milestones, support period alignment with factory agreements, Art. 14 from September 2026.
See before you buy — Download sample dossier (PDF, fictional company) — Real structure, real articles, real format. Fictional data.
Generated from your data, in your browser. No data leaves your device.
CRACheck generates the Art. 31 and Annex VII documentation for the entity classified as manufacturer under Art. 3(13). Whether you are the brand owner in an ODM arrangement or the factory selling under its own brand, CRACheck structures the technical file from your input. Eight documents per product.
CRACheck does not determine which party in your OEM/ODM arrangement is the manufacturer — Art. 3(13), Art. 21 and Art. 22 of Regulation (EU) 2024/2847 make that determination based on your commercial arrangements. CRACheck does not draft OEM/ODM contracts. It does not negotiate data-sharing agreements with factories. It does not assess whether a firmware modification constitutes a "substantial modification" under Art. 22.
The regulation decides who is the manufacturer. CRACheck helps the manufacturer produce the documentation.
The entity classified as manufacturer must have ENISA reporting capability. In dual-manufacturer scenarios (factory + brand owner), each must report independently for products marketed under their respective brands.
Every branded product on the EU market must have a documented manufacturer with Art. 31 documentation. OEM/ODM arrangements without clear manufacturer identification will face enforcement gaps.
Applied to the entity classified as manufacturer. In OEM/ODM, this typically means the brand owner. Contractual indemnification from the factory is a commercial arrangement — it does not change the CRA's enforcement target.
| Criterio | OEM/ODM legal opinion | Factory-provided compliance package | No CRA preparation | CRACheck |
|---|---|---|---|---|
| Price | €8K-25K | Varies, often opaque | €0 | €149 per product |
| Determines manufacturer? | Yes | No | No | No — the law does |
| Produces Art. 31 file? | No | Sometimes, factory format | No | Yes — 8 documents |
| Data stays with you? | Shared with counsel | Factory holds | N/A | 100% browser-side |
| CRACheck | €149 | Yes | 8-doc ZIP | Browser-side |
Pack 10: €99 per product. Pack 30: €79 per product. For OEM/ODM arrangements covering multiple product lines and brand placements, contact us.
Request volume pricingCRACheck generates a structured document set according to Art. 31 and Annex VII of Regulation (EU) 2024/2847 based on the information provided by the entity identified as manufacturer. The accuracy of engineering data — whether sourced from your own development or from an OEM/ODM partner — is the manufacturer's responsibility.
We guarantee that the document structure follows Art. 31 and Annex VII and that the legal references cited are correct. We do not determine which party in an OEM/ODM arrangement is the manufacturer, nor do we guarantee acceptance by a specific authority.
CRACheck is not legal advice. For manufacturer identification in complex multi-party arrangements, consult a qualified EU product compliance lawyer.
If your brand is on the product, you are the manufacturer. Generate the Art. 31 documentation. Eight documents. €149 per product. Browser-side.