Support Periods Under Article 13(8)
CRA Article 13(8) requires manufacturers to determine the period during which vulnerabilities in a product are handled effectively. The period reflects how long the product is expected to be in use.
Five years is the floor rather than the default. Commission guidance C(2026) 5252 point 126 is explicit that the minimum operates only as a safeguard, and that products reasonably expected to stay in use longer need correspondingly longer support periods. The declared period is derived from the expected time in use, and the floor catches only the short tail.
Where to find it
Open a product, then the Documentation tab, then the Annex II user information panel.
What to record
Expected time in use in months. This is the Article 13(8) input, established from reasonable user expectations, the nature of the product and its intended purpose, and any Union law setting a lifetime.
Declared support period in months. Derived from the expected time in use.
Placed on the market. The support period runs from this date. Recording it means the end date stays fixed when you re-save an unchanged figure.
How the period was determined. The written Article 13(8) basis. Saving a period without it is blocked, because a number in the technical file without its reasoning documents a conclusion and not a determination.
Supporting evidence, in the collapsed section. Five fields covering the product lifecycle, comparable products from other manufacturers, hardware lifetime where it bounds the software, contractual commitments, and upstream dependency end-of-life.
Checks the panel applies
These run live as you type and again on save. Blocking issues prevent the save. Warnings do not.
| Condition | Result |
|---|---|
| No Article 13(8) basis recorded | Blocks |
| Exactly 60 months with no expected time in use recorded | Warns that five years is the floor and not a default |
| Declared period shorter than the expected time in use | Blocks |
| Expected use of five years or more, declared period below five years | Blocks |
| Below five years with no supporting evidence | Warns |
| End date and month count disagree by more than a day | Warns |
| Placing on the market not recorded | Warns |
| A substantial modification has not been reflected | Warns |
The same checks run before an assessment snapshot. A product cannot be recorded as placed on the market with no declared support period.
After a substantial modification
Each substantially modified version needs its own declared support period under Article 13(8). Guidance points 133 to 135 are equally clear that a substantial modification does not by itself reset or extend the period.
The question is whether the modification changed the factors that originally set the expected time in use. A software feature update to a device whose lifetime is set by hardware durability does not. Replacing that hardware with a longer-lived platform does.
The panel warns until you either re-derive the period or record that the factors did not change. It deliberately does not force an extension, because reflexive extension is the error the guidance warns against. See Substantial Modification Assessments.
Where the period appears
The declared period, the end date and the recorded basis all flow into the generated Annex II user-information sheet under section 7. The basis also satisfies item 4 of the Annex VII technical documentation index, which asks for the information used to determine the support period.
Article 13(19) separately requires the end date to be given to the user at the time of purchase, and a notification to be shown once the period expires where that is technically feasible.