Answer:

Regardless of the question of support, the question of the applicability of the CRA for legacy products is answered depending on the date of sale (see FAQ "Does the CRA apply to products that were placed on the market for the first time before December 11, 2027, but which are still offered by the manufacturer in an unmodified state after that date?").

Another relevant question is whether a product with digital elements is integrated into the old product as part of support and whether the exception for "spare parts" applies.

Two scenarios must be considered if the old product is no longer sold after the CRA comes into force and repairs using spare parts become necessary as part of support:

1. If the spare part is installed as a replacement for an identical part, this does not trigger any obligations under the CRA, unless the nature of the risk has changed or the cybersecurity risk has increased due to a software update (see Recital 39).
2. If a part is installed as a replacement for an old part and includes new functionality, the CRA applies to the substantially modified old product (see also FAQ "How do product modifications affect the applicability of the CRA?").

CRA; Legacy product; Spare part

Most recent content update of this FAQ: September 2025

Next FAQ: What is the difference between “placing on the market” and “making available on the market” with regard to legacy products?