Identification of Economic Operators (Art. 21)

Overview

Art. 21 CRA requires all economic operators to be able to identify their suppliers and customers within the supply chain. This information must be provided to market surveillance authorities upon request. The objective is to ensure complete traceability of products with digital elements across the entire supply chain.

LEGAL BASIS

Art. 21 CRA: "Economic operators shall, on request, identify the following to the market surveillance authorities:

• any economic operator who has supplied them with a product;
• any economic operator to whom they have supplied a product.

Economic operators shall be able to present this information for a period of 10 years after they have been supplied with the product and for 10 years after they have supplied the product."

Affected Economic Operators

The identification obligation applies to all roles in the supply chain:

Economic Operator	Identification Obligation	Reference
Manufacturer	Customers (importers, distributors)	Art. 10, Art. 21
Importer	Manufacturer (supplier) + distributors (customers)	Art. 15, Art. 21
Distributor	Importer/manufacturer (supplier) + customers	Art. 17, Art. 21
Authorised Representative	Manufacturer (principal) + customers	Art. 16, Art. 21

Documentation Requirements

Minimum Record Contents

The following data must be maintained for each CRA-relevant transaction:

• Identity of the supplier or customer (company name, address, contact details)
• Product designation (type, version, serial number or unique identifier)
• Date of supply or receipt
• Quantity and type of products supplied

Retention Period

RETENTION OBLIGATION

All identification records must be retained for at least 10 years from the date of supply and must be available to market surveillance authorities upon request.

BAUER GROUP Implementation

Incoming Supply (Suppliers)

Measure	System	Status
Supplier master data	ERP / Procurement system	✅
Goods receipt recording with product allocation	ERP	✅
Archival of procurement documents	DMS	✅
Retention period ≥ 10 years configured	DMS / ERP	⚠️ To be verified

Outgoing Supply (Customers)

Measure	System	Status
Customer master data	ERP / CRM	✅
Order processing and delivery documentation	ERP	✅
Archival of sales and distribution documents	DMS	✅
Retention period ≥ 10 years configured	DMS / ERP	⚠️ To be verified

Process for Authority Requests

1. Request from market surveillance authority is received
2. Forwarding to ISB and the responsible department
3. Identification of the affected product and relevant transactions
4. Compilation of supplier and customer data from ERP/DMS
5. Submission to the authority within the specified deadline

Checklist

• [ ] ERP retention periods for supplier and customer data verified at ≥ 10 years
• [ ] DMS archival policies for procurement and sales documents updated
• [ ] Process for authority requests regarding economic operator identification documented
• [ ] Responsibilities for responding to Art. 21 requests defined
• [ ] Regular review of data quality in master data systems

Cross-References

• Supply Chain Security -- Overview of supply chain security measures
• Market Surveillance -- Cooperation with authorities and response processes
• Importer Obligations -- Specific obligations for non-EU suppliers
• Distributor Obligations -- Due diligence obligations for distribution