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Manufacturer identification — CRA Annex II / Art. 13

This page is the manufacturer-identification record — part of the information and instructions to the user set out in CRA Annex II (obligation: Art. 13(18)) — and records the single point of contact designated under Art. 13(17) for the CRE8EVE-shipped SDKs.

Keep in sync with /SECURITY.md § Manufacturer Identification. The legal-entity facts below are rendered from one canonical record (verified against the Polish KRS register). If a registration fact changes, update that record first; this page and SECURITY.md are renders of it, never a fork.

FieldValue
Legal entityCRE8EVE Sp. z o.o.
Legal formSpółka z ograniczoną odpowiedzialnością (limited liability company)
Registered postal addressTulipanowa 4, 72-003 Dobra, Poland
EU establishmentPoland (EU Member State)
RegisterKRS 0000912669 — Sąd Rejonowy Szczecin-Centrum w Szczecinie, XIII Wydział Gospodarczy KRS
Tax identifiersNIP 8513262229 · REGON 389506637
Single point of contactsecurity@rakomi.com (role-based address — no personal mailbox or phone is published)

EU establishment — no Authorised Representative required

Section titled “EU establishment — no Authorised Representative required”

CRE8EVE Sp. z o.o. is itself established in the European Union (Poland). Under CRA Art. 18, the obligation to appoint an EU-established authorised representative applies only to manufacturers established outside the Union. Because the manufacturer is EU-established, no Art. 18 authorised representative is required — the manufacturer fulfils the manufacturer obligations directly.

CRE8EVE is governed by a two-director Management Board (Zarząd):

  • Bogumil Wrona — President of the Management Board (Prezes Zarządu)
  • Agnieszka Wrona — Member of the Management Board (Członek Zarządu)

The two-director board is recorded here as a continuity and availability signal, not merely a legal field: vulnerability-handling decisions and the single point of contact remain operable if one director is unavailable (succession / break-glass). It is the same dual-authority posture used across CRE8EVE’s governance controls.

The four customer-shipped SDK packages are classified under CRA Annex III as Class I important products (identity-management software):

PackageEcosystemSource
@rakomi/nodenpm (JS family)packages/sdk/
@rakomi/sdk-corenpm (JS family)packages/sdk-core/
@rakomi/reactnpm (JS family)packages/react/
@rakomi/react-nativenpm (JS family)packages/react-native/

The native lines RakomiSDK (Swift) and rakomi_flutter (Dart) are CRA-scoped manufacturer products as well; their distribution and per-package accompanying documentation are tracked separately (native SDK distribution work) and are not yet published.

The in-scope SDKs are Class I important products under CRA Annex III. Under Art. 32(2), a Class I important product may use the internal-control procedure (Annex VIII, Module A — manufacturer self-assessment, no notified-body involvement) only where harmonised standards, common specifications, or a European cybersecurity certification scheme (assurance level at least “substantial”) covering the essential cybersecurity requirements are applied in full. Where they are not, a third-party route is required — EU-type examination plus conformity to type (modules B+C) or full quality assurance (module H), per Annex VIII. The applicable route will be confirmed against the harmonised standards in force at the CRA application date.

The EU Declaration of Conformity and CE marking attach at the CRA application date (December 2027) per the CRA application timeline (Art. 71); they are not yet issued. Publishing a pre-1.0 (0.x) package today is a forward-looking distribution and is not a present conformity claim.

The coordinated vulnerability-disclosure policy, response targets, and reporting channel are defined once in /SECURITY.md and published in machine-readable form at https://rakomi.com/.well-known/security.txt. The operational reporting capability (national CSIRT identification, EU single-reporting-platform onboarding, statutory filing timelines) is being stood up separately as part of CRA Art. 14 reporting readiness; this documentation describes the policy and intent.