However you do not have to be the distributor -

Wondering if I'd be a "manufacturer" instead ? There are many obligations for the manufacturer in the CRA...

"manufacturer’ means any natural or legal person who develops or manufactures products with digital elements or has products with digital elements designed, developed or manufactured, and markets them under his or her name or trademark, whether for payment or free of charge;"

So because of the end precision, "markets them under his or name or trademark", maybe not me, but the project / OSGeo itself.


the customer self-serves from the open-source distribution. In this case the project - specifically the steering committee (acting on behalf of osgeo) are on the hook for a lot of these reg requirements.

That's a major issue. Members of steering committees are unpaid volunteers. They are more or less active. With our current organization, they are not in a capacity to face regulation requirements. Basically that would mean that projects should have salaried members, at least part-time, to do that.


--
http://www.spatialys.com
My software is free, but my time generally not.

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