The "Blue Guide" will tell you what you need to know: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2022.247.01.0001.01.ENG
2.2. Making available on the market
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A product is made available on the market when supplied for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge.
Thanks, that was indeed the piece I had missed. I was going by the definition of "placing on the market" which had been quoted earlier. I did check the actual Blue Guide and read the text around that definition, looking for additional scope delimitations, but did not find any there. Now it's clear that they are in the separate clause you quoted.
I am sure the blessed directive also explains somewhere why it needs separate definitions of "Making available on the market" and "Placing on the market", but I don't care quite enough to try and understand that work of bureaucratic art.