

The OS or a phone both fit that definition.
Yes it does, and it means someone making and selling either has to have a certain level of knowledge about it supply chain.
An app fits the definition of a component.
If it’s bundled with the OS, it probably does. In that case, the OS vendor is a manufacturer and has a variety of obligations relative to the app detailed in article 13.
If the user is obtaining it directly from the developer and installing themselves, it doesn’t really matter if it’s a component or a product because the OS vendor is not distributing or manufacturing anything. If the app/OS combination were to be treated as a system of which the app is a component, it is the user who has manufactured that product by combining the two. If the user is not selling that system, they have no obligations under the CRA.




The who has supplied them part is the critical point here.
I’ll give an example outside of digital technology. If Ford sells a car with Michelin tires on it, Ford has some responsibility for those tires even though I can also buy them from Joe’s Tire Shop and put them on any car with the right size wheels. I can also buy Continental tires from Joe’s Tire Shop and put them on my Ford car. Ford has no responsibilities in relation to Continental Tires or Joe’s Tire Shop.
If Samsung preloads WhatsApp and Android on a phone, Samsung has to know where it got WhatsApp and Android. If I download Signal from https://signal.org/android/apk/ and install it on a Samsung phone running Google Android, neither Samsung nor Google is a party to that.
The CRA, including the parts you’re quoting does not impose any obligation on anyone with respect to a product or component they never touch.