The kit stated in eleven places that a non-EU manufacturer must appoint an EU Authorised Representative. CRA Art. 18(1) says "a manufacturer may, by a written mandate, appoint an authorised representative"; there is no "shall appoint" anywhere in Regulation (EU) 2024/2847. Nor is there a backdoor via market surveillance. CRA Art. 66 adds the CRA to Annex I of Reg (EU) 2019/1020, but Art. 4 of that regulation is triggered by its own closed list in Art. 4(5), which the CRA does not amend. Batteries Reg 2023/1542 Art. 91 and the Critical Raw Materials Act both amended Art. 4(5) and Annex I together when they wanted Art. 4 to apply; the CRA amended Annex I only. State wolfSSL Inc.'s position affirmatively: the three Art. 18(3) tasks are discharged directly, under Art. 13(13) (identical retention duty and clock), Art. 13(16) and Art. 13(17). Correct the customer-facing guidance to say Art. 18 is discretionary under the CRA while noting that other EU acts covering finished products may require a representative outright. |
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|---|---|---|
| .. | ||
| wolfssl-component | ||
| wolfssl-component-embedded | ||
| 00-INDEX.md | ||
| README.md | ||
| product-acme-connect-gateway.cdx.json | ||
| product-acme-connect-gateway.spdx.json | ||
README.md
Sample auditor packet
This directory is a teaching example only. Acme Industries and acme-connect-gateway are fictional.
It shows how a product SBOM references wolfSSL’s component SBOM in both CycloneDX and SPDX forms.
See 00-INDEX.md for the file list.