If we consider FPC/Lazarus open source, managed (my thinking) by a nonprofit organization (Free Pascal and Lazarus Foundation), then this falls outside the CRA. The problem falls solely on those who use Lazarus/FPC, who must demonstrate compliance with the CRA.
(the previous words are mine, apologies if there is no adherence to what is reality).
This is one of the reasons that pushed me to stick with Delphi (without detracting from any responsibilities)... Embarcadero is obligated to maintain the product as long as it markets it (this is for CRA purposes), and therefore the responsibility for the product lies with them.
Obviously, its use and production falls on the developer, but at least their back is covered.
In any case, there's still much more to write about. It's a long road to its final implementation (in any case, I'm already doing the SBOM... you never know).