wolfssl-examples/cra-kit/auditor-packet
Mark Atwood f904bdcc80 docs(cra-kit): Art. 18 AR is discretionary, not required
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.
2026-08-21 13:06:33 -07:00
..
wolfssl-component cra-kit: address Atwood re-review blockers on #574 2026-07-02 17:50:01 +03:00
wolfssl-component-embedded cra-kit: address Atwood review (shell safety, validation, samples) 2026-06-17 17:27:15 +03:00
00-INDEX.md docs(cra-kit): Art. 18 AR is discretionary, not required 2026-08-21 13:06:33 -07:00
README.md cra-kit: fix commercial-license SBOM generation and refresh samples 2026-06-22 13:40:11 +03:00
product-acme-connect-gateway.cdx.json cra-kit: address Atwood re-review blockers on #574 2026-07-02 17:50:01 +03:00
product-acme-connect-gateway.spdx.json cra-kit: address Atwood re-review blockers on #574 2026-07-02 17:50:01 +03:00

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.