In the context of the CRA, does the support period start from the date of initial release on the market, or does it start for each individually purchased product upon purchase?

Answer:

The general support period starts for the date of “placing on the market”. So, while there might be different starting dates of support periods for the individual customers, the relevant support period under the CRA starts with the date the product with digital elements is placed on the market for the first time. As noted, a proper release management and agreements around support periods are advised.

E.g. please make sure that the duration of support periods sold to customers remains within the boundaries of the product's defined support life-cycle. For this a clear communication between product management and sales teams is essential to prevent contractual commitments that extend beyond the product's official support period, as such agreements would create binding obligations that must be fulfilled regardless of CRA compliance timelines or internal product roadmaps.

Most recent content update of this FAQ: September 2025

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