Building under your own name makes you the manufacturer Art. 3(13)
The CRA defines a manufacturer as anyone who develops or manufactures a product, or has it designed, developed, or manufactured, and then markets it under its own name or trademark, whether for payment, monetisation, or free of charge (Art. 3(13)). An agency that writes an app for a client and ships it under the agency brand fits that definition squarely.
The "has it developed" wording matters for agencies that subcontract. Outsourcing the actual coding does not move manufacturer status to the subcontractor if you are the one putting the product on the market under your name. The obligations follow the name on the product, not the keyboard it was typed on.
White-labelling and substantial modification carry the same weight Art. 21, Art. 22, Art. 3(30)
If you take another company's product and place it on the EU market under your own name or trademark, you are treated as the manufacturer and become subject to Articles 13 and 14, even though you did not build it (Art. 21). This is the classic white-label trap: a reseller badge turns into a full manufacturer obligation set.
The same applies if you substantially modify a product already on the market and then make it available (Art. 22). A substantial modification is a change after placing on the market that affects compliance with the essential cybersecurity requirements or changes the intended purpose the product was assessed for (Art. 3(30)). Reskinning is unlikely to qualify; re-architecting or bolting on new connected features may well.
Bespoke, single-client software Art. 3(22), Recital 64, Annex I Part I, Annex I Part II (8)
There is no carve-out for custom work. "Making available on the market" means supplying a product for distribution or use in the course of a commercial activity, whether paid or free (Art. 3(22)). Delivering a tailored system to one business client for their use is supply in the course of business, so the sensible default is that it is in scope and you are its manufacturer.
The CRA does leave one narrow door. Its recitals let a manufacturer deviate from the essential requirements for tailor-made products fitted to a particular purpose for a particular business user, where both sides have explicitly agreed a different set of contractual terms (Recital 64). This is a limited relief on the requirements, not an exit from scope, and it should be papered carefully.
Judgment call: The tailor-made deviation appears in Recital 64 and in carve-outs within Annex I (Part I and Part II (8)) for products made to order for a business user; its exact reach is untested. Treat it as a documented, negotiated exception, not a blanket exemption for custom builds.
Reselling without touching the product is lighter Art. 20, Art. 21
If you resell or distribute a product without changing it and without putting your own brand on it, you are a distributor, not a manufacturer, and you carry the lighter due-care duties instead (Art. 20). The moment you rebrand it or modify it substantially, you flip back into the manufacturer obligations, so the safe habit is to know which hat you wear on each engagement.