CLAIM-2026-08-24-07

The CRA reporting duty applies to manufacturers of products with digital elements marketing in the EU, including non-EU companies; non-commercial open-source software is out of scope, but once open-source software is integrated into a product supplied commercially, the manufacturer must exercise due diligence.

Why it matters

An agent product that bundles an open-source MCP server does not inherit the OSS exemption - the integrator owns the due-diligence and reporting duty.

Sources

  • europeancom2026cra
  • crowellmori2026eu