Thomas Cutuil

Certification engineer — EU product compliance expert

PhD in physics. Ten years at the DGCCRF. In-post product certification manager. A rare profile, for subjects that leave no room for approximation.

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Latest articles

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ANFRCRAConformitéContrôle de marchéDDADUE

DDADUE Article 32: ANFR to be designated as France's CRA authority

The DDADUE bill, adopted by the Senate under accelerated procedure, formally designates ANFR as France's market surveillance authority for the CRA. Article 32 inserts a new I quinquies into Article L.43 of the CPCE, sets out the mise en demeure → fine sequence, and codifies the three CRA sanction tiers (up to €15M or 2.5% of worldwide turnover). Two points deserve particular attention: trade secrets are not opposable to ANFR in CRA investigations, and the entry into force is split, ANFR mission on 11 September 2026, sanctions regime on 11 December 2027.

1 May 2026 6 min

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CRAConformité CECybersécuritéDirective REDEN 18031

The RED cyber DA is repealed: the CRA takes over on 11 December 2027

Commission Delegated Regulation (EU) 2026/339, published in the Official Journal on 29 April 2026, repeals Delegated Regulation (EU) 2022/30 with effect 11 December 2027 — the date of full CRA application. There will be no regulatory double-obligation: radio equipment manufacturers who have been working toward EN 18031 compliance since August 2025 are covered until that date, and the CRA takes over exclusively. What the repeal resolves, what it does not, and how to sequence the transition.

1 May 2026 6 min

CRA market surveillance: the ANFR perspective

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ANFRArticle 14CRAConformité CEContrôle de marchéDue diligence

CRA market surveillance: the ANFR perspective

For manufacturers of connected radio products, the authority that matters for both the RED directive and the CRA is ANFR, not DGCCRF. Both regulations are enforced by the same small team of inspectors, operating with a resource constraint that shapes enforcement into a model of exemplary cases. Article 14 creates an investigation channel that did not exist before: a manufacturer who notifies a vulnerability becomes visible to ANFR; one who does not, becomes exposed when the flaw becomes public. What ANFR looks for in a CRA technical file, what triggers a control, and why the CRA sanction regime changes the risk calculus for investors.

30 April 2026 12 min

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CE regulatory compliance expert, with cross-experience on the enforcement side (DGCCRF, 2014–2024) and the industrial side (product certification since 2025). Working on complex cases: technical file audits, product regulatory due diligence, pre-litigation technical support.

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Consulting services

CE compliance audit

Technical file analysis, identification of gaps against harmonised standards and applicable regulation, structured report. 3–5 days.

Regulatory due diligence

Assessment of the regulatory risk of a product portfolio in an M&A or investment context. Structured risk memo. 2–4 days.

Pre-litigation support

Building the technical position facing a market surveillance authority or a buyer. Structured technical note. 2–5 days.

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