Declare and disclose the product support period

Article 13(8) of Regulation (EU) 2024/2847 requires that the support period for a product with digital elements shall be at least five years from the date of placing on the market, unless the expected use period of the product is shorter.

Manufacturers must indicate the support period in a prominent manner and must ensure this information is accessible to users at the time of purchase and in the Annex II user information accompanying the product.

1. Minimum 5-year support period — or expected use period if objectively shorter
2. Support-period end date disclosed — specific date, not just "5 years"
3. Pre-purchase disclosure — visible at point of sale (product listing, packaging)
4. Annex II information — support period end date included in the information provided to users (see OBL-ART13-16 on Annex II generally)
5. Per-version declaration — for products with multiple versions in the market, each version must have its own declared support end date

The March 2026 draft Commission guidance (non-binding, status: draft) clarifies:

• Five years is a floor, not a default — for products typically used for longer (e.g. industrial equipment, smart meters), the support period must match the expected use period
• Support period is calculated per version placed on the market, not from last sale
• For software-only products with continuous release cycles, the guidance suggests per-version support declarations aligned with release cadence

• Support period declaration in product documentation and sales materials
• Version-specific support end dates
• Internal policy governing support period determination
• Records showing the declared period meets the 5-year minimum (or shorter expected use period rationale)