Method / the scope engine
The 37-profile regression table
Every expected value below was written from the article text before the engine was run. Each row names the provision that justifies it. The table is the guard against the two ways a scope check goes wrong: a lighter answer for an unknown fact, and a product wrongly swept into a service exemption.
| Case | Profile | Expected verdict | Must include | Why, with the provision |
|---|---|---|---|---|
| R01 | manufacturer; products: Consumer general purpose computer hardware | in scope | Annex I, Section I; Annex I, Section II; Article 7 | Article 2(1)(a): general purpose hardware is a product; Article 4(2) gives Section I and Section II; Article 7 gives manufacturer duties. |
| R02 | manufacturer; products: Payment terminal at a physical point of sale | in scope | Annex I, Section I; Article 7 | Article 4(2): Section II does not apply to self-service terminals; Article 2(1)(b)(i) payment terminal is one. |
| R03 | manufacturer; products: E-reader | in scope | Annex I, Section I; Annex I, Section II | Article 2(1)(e): an e-reader is a product and not a self-service terminal, so Sections I and II apply. |
| R04 | manufacturer; products: Consumer general purpose computer hardware | out of scope | none | Article 2(1): the product duties reach models first supplied in the Union from 28 June 2025. A model first placed before that date is outside. |
| R05 | importer; products: Operating system for that hardware | in scope | Article 9 | Article 9: importer verifies and places only compliant products. |
| R06 | distributor; products: Ticketing machine | in scope | Article 10; Annex I, Section I | Article 10: distributor duties; Article 4(2) removes only Section II for a ticketing machine. |
| R07 | service provider; services: E-commerce services; microenterprise: yes | out of scope | Article 4 | Article 4(5): a microenterprise providing services is exempt from the Article 4(3) requirements and related obligations. |
| R08 | manufacturer; products: Consumer general purpose computer hardware; microenterprise: yes | in scope | Article 7; Annex I, Section I | Article 4(5) exempts microenterprises providing services only. A product placed on the market still carries the Article 7 duties. |
| R09 | service provider; services: Consumer banking services; microenterprise: unknown | incomplete | none | The microenterprise test in Article 3(23) has two limbs; an unknown answer cannot be defaulted to the lighter pathway. |
| R10 | service provider; services: E-commerce services; microenterprise: no | in scope | Annex I, Section III; Annex I, Section IV; Article 13; Annex V | Article 4(3): a non-exempt e-commerce service meets Section III and Section IV; Article 13 and Annex V add the information duties. |
| R11 | service provider; services: Urban, suburban or regional transport; microenterprise: no | in scope | Annex I, Section IV; Article 13 | Article 4(3) excludes urban, suburban and regional transport from Section III; Section IV(d) still applies to its terminals. |
| R12 | service provider; services: Consumer banking services; microenterprise: no | in scope | Annex I, Section IV; Annex I, Section III | Annex I Section IV(e): consumer banking carries the identification, signature, security and payment duties and the CEFR B2 information limit. |
| R13 | service provider; services: E-books and dedicated software; microenterprise: no | in scope | Annex I, Section IV | Annex I Section IV(f): e-books carry the file, navigation, metadata and DRM duties. |
| R14 | public safety answering point; answers 112 | in scope | Annex I, Section V | Article 4(8) and Annex I Section V: the 112 duty; Article 31(3) allows 2027 only where the member state uses the derogation. |
| R15 | public safety answering point; answers 112; microenterprise: yes | in scope | Annex I, Section V | The microenterprise exemption in Article 4(5) is for service requirements, not the Article 4(8) 112 duty. |
| R16 | manufacturer | out of scope | Article 2 | Nothing in Article 2(1), 2(2) or 2(3) is selected, so the facts do not bring the organisation into scope. |
| R17 | no role | incomplete | none | Without a role the engine has no basis for a duty; it must return incomplete, not a guess. |
| R18 | manufacturer; products: Consumer general purpose computer hardware | incomplete | none | The first placing date decides Article 2(1); a missing answer is incomplete. |
| R19 | manufacturer; products: Consumer general purpose computer hardware; exception: burden | in scope | Article 14; Annex VI | Article 14(6): funding provided to improve accessibility bars the disproportionate-burden route. |
| R20 | service provider; services: E-commerce services; microenterprise: no; exception: burden | in scope | Article 14; Annex VI | Article 14(2), (3), (5) and Annex VI: an unfunded burden claim needs the criteria, retention and five-year renewal. |
| R21 | manufacturer; products: E-reader; exception: fundamental | in scope | Article 14 | Article 14(1)(a): a fundamental alteration is a significant change to the basic nature of the product or service. |
| R22 | service provider; services: Consumer banking services; microenterprise: no; built environment option: applied | in scope | Annex III | Article 4(4): Annex III applies only where the member state has decided to apply the built-environment option. |
| R23 | service provider; services: Consumer banking services; microenterprise: no | in scope | none | Article 4(4) is a national option; an unknown answer must be flagged, not assumed either way. |
| R24 | service provider; products: Consumer terminal equipment for electronic communications; services: E-commerce services; microenterprise: no | in scope | Article 7; Article 13 | Article 11: a service provider that places a product under its own name or modifies it takes on the Article 7 duties. |
| R25 | service provider; services: Services giving access to audiovisual media; microenterprise: no | in scope | Article 13; Annex V | Article 13: a service-only provider has service duties and no Article 7 product duty. |
| R26 | manufacturer and importer; products: Consumer terminal equipment for audiovisual media; services: Air passenger transport; microenterprise: no | in scope | Article 7; Article 9; Article 13 | Article 9 and Article 7: an operator that both manufactures and imports carries both sets. |
| R27 | service provider; services: Urban, suburban or regional transport; E-commerce services; microenterprise: no | in scope | Annex I, Section III; Annex I, Section IV | Article 4(3): an urban service escapes Section III, but the e-commerce service in the same profile does not. |
| R28 | manufacturer; products: Interactive information terminal | in scope | Annex I, Section I | Article 4(2): an interactive information terminal is a self-service terminal under Article 2(1)(b)(ii), so Section II is disapplied. |
| R29 | service provider; services: Electronic communications services; microenterprise: yes | out of scope | Article 4 | Article 4(5) and Article 3(23): nine staff and a EUR 1.9 million turnover meets the microenterprise test, so the service duties are exempt. |
| R30 | service provider; services: E-books and dedicated software; microenterprise: no; exception: burden | in scope | Article 14; Annex VI | Article 14(6): an unknown funding position cannot be treated as unfunded; the engine flags the bar and keeps the duty in scope. |
| R31 | manufacturer; products: E-reader; services: E-commerce services; microenterprise: yes | in scope | Article 7; Annex I, Section I | Article 4(5) exempts a microenterprise from service duties only. A product placed by the same operator keeps the Article 7 duties, so the verdict cannot be 'outside the scope'. |
| R32 | service provider; services: E-commerce services; Consumer banking services; microenterprise: no | in scope | Article 13; Annex V | Article 13(1) and (2) and Annex V: a service provider's result must name the service duties, not only Article 31. |
| R33 | public safety answering point; answers 112 | in scope | Annex I, Section V; Article 4 | Article 4(8) and Annex I Section V: a PSAP result must name the 112 duty, not only Article 31. |
| R34 | manufacturer; products: Interactive information terminal | in scope | Annex I, Section I | Article 2(1)(b)(ii) covers an interactive self-service information terminal other than one built into a vehicle, aircraft, ship or rolling stock; it is a self-service terminal, so Section II is disapplied. |
| R35 | service provider; services: E-commerce services; microenterprise: no; exception: undecided | in scope | Article 14 | Article 14(2) and (3): an exception is not established until the assessment is done and documented; an undecided answer must be flagged, not planned on. |
| R36 | manufacturer; products: Consumer general purpose computer hardware; built environment option: applied | in scope | none | Article 4(4) is an option about the built environment where a service is delivered; a product-only profile is not touched by Annex III. |
| R37 | manufacturer; products: Consumer terminal equipment for electronic communications; services: E-commerce services; microenterprise: no | in scope | Article 7; Article 13; Annex V | A manufacturer that also provides a non-exempt service carries the Article 7 product duties and the Article 13 service duties. |
How to reproduce it
The engine is /engine.js, a pure function with no network and no model call. The cases are data/scope_cases.json, and node scripts/test_scope.mjs runs them. A change to the engine that breaks a row fails the release gate.