No. 72: Commission Guidance on the CRA - Infinite Support Periods
The Commission guidance creates an infinite support period: Substantial modifications imply new placing on market, which restarts the support period over and over again. I refute the first implication with the CRA itself and show how to legally shorten the support period.
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Real and Imagined Consequences of Substantial Modifications
WRONG: substantial modification => new placing on the market. Logical somersaults needed to avoid infinite support periods and full conformity assessment for all legacy products. --- RIGHT: substantial modification => update conformity assessment. No trickery needed.
No, Light-Touch or Full CRA Compliance for FOSS Components
Do suppliers of FOSS components like Qt LGPL, Weston/Wayland, Linux BSPs, containers and OTA update solutions have to perform no, light-touch or full CRA compliance? The answer affects how much due diligence machine and device manufacturers must exercise for these components in their CRA compliance.