A market-entry timing term for the first making available of a product, battery, commodity or relevant product in a regulated market.
Readers often treat market entry as a sales milestone, but regulators use it as an obligation trigger. The implementation risk is that passport records, declarations, or due-diligence evidence are assembled after the product is already in scope.
This is a source-specific timing term. ESPR, the EU Battery Regulation, EUDR, and the EU Critical Raw Materials Act all use first making available wording, but each source defines the relevant object and obligation scope. The UK Batteries Placing on Market Regulations use a separate battery-market definition that also refers to supply or availability in the European Economic Area and import into the customs territory of the Community. PPWR context: Regulation (EU) 2025/40 defines packaging, packaging waste, prevention, reuse/refill systems, recyclability, and packaging actor roles for the EU packaging regime. Do not collapse PPWR producer/manufacturer/importer/distributor or market-entry wording into other product, battery, waste, or ELV source meanings.
Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products
the first making available of a product on the Union market;
Reference: Article 2, point 40
Regulation (EU) 2023/1542 concerning batteries and waste batteries
the first making available of a battery on the Union market;
Reference: Article 3, point 16
Regulation (EU) 2023/1115 on deforestation-free products
the first making available of a relevant commodity or relevant product on the Union market;
Reference: Article 2, point 16
The Batteries and Accumulators (Placing on the Market) Regulations 2008
supplying or making available, whether in return for payment or free of charge, to a third party within the European Economic Area and includes import into the customs territory of the Community as defined in Article 3 of Regulation 450/2008/EC of the European Parliament and of the Council laying down the Community Customs Code, and “place on the market” and “placed on the market” shall be construed accordingly
Direct UK regulation definition from the interpretation provision for placing batteries and accumulators on the market.
Reference: Regulation 2(1)
Regulation (EU) 2024/1252 establishing a framework for ensuring a secure and sustainable supply of critical raw materials
the first making available of a product on the Union market
CRMA Article 2 source-specific definition layer.
Reference: Article 2, point 61
Regulation (EU) 2025/40 on packaging and packaging waste
the first making available of packaging, whether empty or with a product, on the Union market
Reference: Article 3, point 10
Placing on the market is the first market-entry event that makes a regulated product, battery, commodity, or raw-material-related product available on the Union market. It sets the timing point for obligations; it is not the same as conformity assessment and does not prove later distribution, customer delivery, or completion of every compliance process.
UK context: UK Batteries Placing on Market Regulations defines this term in UKSI 2008/2164. Keep this UK source layer separate from EU or other jurisdiction definitions where scope and obligations differ.
Use a market-entry event record with a product identifier, relevant source law, actor record, jurisdiction, first-availability date, linked declaration, passport-readiness check, and readiness decision. The record should show which evidence had to exist before downstream sale, later availability, or later delivery events are separate.
Placing on the market is a market-entry control: product identity, responsible actor, source-law scope, and supporting evidence need to be linked before the obligation trigger. The control should not be used as a proxy for conformity assessment, due-diligence completion, or passport completeness.
EU product regulation uses a layered actor model: manufacturer → authorised representative → importer → distributor → economic operator (umbrella). Each actor in this chain has different obligations, and the applicable obligations depend on which regulation is in play. A company should determine its actor status independently under each applicable regulation, as the same entity can be a manufacturer under one regulation and a distributor under another.