The support period for which the manufacturer ensures the effective handling of vulnerabilities should be no less than five years, unless the lifetime of the product with digital elements is less than five years, in which case the manufacturer should ensure the vulnerability handling for that lifetime. Where the time the product with digital elements is reasonably expected to be in use is longer than five years, as is often the case for hardware components such as motherboards or microprocessors, network devices such as routers, modems or switches, as well as software, such as operating systems or video-editing tools, manufacturers should accordingly ensure longer support periods. In particular, products with digital elements intended for use in industrial settings, such as industrial control systems, are often in use for significantly longer periods of time. A manufacturer should be able to define a support period of less than five years only where this is justified by the nature of the product with digital elements concerned and where that product is expected to be in use for less than five years, in which case the support period should correspond to the expected use time. For instance, the lifetime of a contact tracing application intended for use during a pandemic could be limited to the duration of the pandemic. Moreover, some software applications can by nature only be made available on the basis of a subscription model, in particular where the application becomes unavailable to the user and is consequently not in use anymore once the subscription expires.
Recital 60
Regulation (EU) 2024/2847 — published 10 December 2024 · Last reviewed by Kunnus: March 2026
European Commission Interpretation
Guidance of 27 July 2026The EU Commission guidance of 27 July 2026 provides official interpretation notes on this provision. Each section: summary, key takeaways, and what it means for you in practice.
Section 5 – 5.1Support period — determination, Art. 13(10) and substantial modifications
Five years is a floor, not a default: the support period reflects the expected use time, and products expected to be used longer need longer support. Article 13(10) allows manufacturers to address and remediate vulnerabilities only for the version last placed on the market, provided users can upgrade free of charge and without additional costs. A substantial modification does not automatically reset the support period.
Key takeaways
- 'Additional costs' under Art. 13(10) means mandatory hardware purchases or infrastructure replacement — not normal update effort such as personnel time, testing or configuration adjustments.
- Each substantially modified version needs its own declared support period under Art. 13(8) when placed on the market.
- Where unchanged factors (e.g. hardware durability) continue to determine the expected use time, the original support period stands — even where the remainder is less than five years (Examples 54/55: robot vacuum, industrial machinery with re-architected cloud back-end).
- Where the modification changes the use-time factors themselves (e.g. a new computing platform extends a PLC's life), the support period must be recalculated (Example 56).
- Indicate the support end date at the time of purchase (at least month/year) and display an end-of-support notification where technically feasible (Art. 13(19)).
- Manufacturers may voluntarily keep patching earlier versions — including on a paid basis; the CRA does not require free updates for them.
In practice
Derive the support period from the expected use time with documentation — a blanket '5 years' is attackable where your product is evidently used longer. State the end date in the purchase process (at least month/year). For software: check whether the Art. 13(10) rule lets you patch only the latest version — that requires free upgrades without forced hardware or infrastructure changes.
EU Commission Guidance (C(2026) 5252 final) — The guidance reflects the European Commission's interpretation and is not legally binding. An authoritative interpretation of the EU CRA may only be given by the Court of Justice of the European Union.
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(1)This text is reproduced from Regulation (EU) 2024/2847 of the European Parliament and of the Council of 23 October 2024. It is provided for informational purposes only and does not constitute legal advice. Only the text published in the Official Journal of the European Union is legally binding. Original text on EUR-Lex