Many TI customers operate through a Tier 1 board manufacturer or SoM vendor that bridges between TI and the OEM. When the Tier 1 or SoM vendor places a board or module on the EU market under its name, that vendor is a manufacturer and carries CRA requirements. When the vendor operates as a contract manufacturer under OEM direction without placing a product on the market under their name, CRA manufacturer obligations fall entirely on the OEM. Similarly, in a chip-down design, the OEM integrates TI silicon directly with no Tier 1 or SoM vendor in between, so the OEM alone carries product level obligations.

A Tier 1 or SoM vendor acting as a manufacturer must generate a board-level SBOM that incorporates TI's SDK SBOM, maintain its own CVD policy and disclosure contact, and provide security documentation to downstream integrators.

Selecting a board or module from a Tier 1 vendor with CRA compliance processes does not remove the OEM's requirement to perform a product-level risk assessment, produce a product-level SBOM, and declare conformity for the finished product. Each role's requirements attach to the product they place on the market under their name.