European Data Act

From September 12, 2025, the European Data Act (EU Data Act) will apply. This European law obliges you to inform consumers beforehand about the data collected by connected items, such as smart devices. Examples include robot vacuum cleaners, smartwatches (or other fitness equipment), smart lighting (controllable via app), or other household appliances with an internet connection (including washing machines, baby monitors, scales, doorbells, thermostats, refrigerators). As a partner, you are solely responsible for providing this information. We will help you with an explanation and a convenient upload option.

The EU Data Act (known in Dutch as ‘Dataverordening’) is a new European law that focuses on data sharing. The law addresses data collected by connected items, such as smart devices with an internet connection.

The goal of the EU Data Act is to make this data more accessible to users, including your customers, so they can gain more insight and control over the data their devices generate.

Do you sell connected items? Then you will be obliged to inform your customers before purchase about what data the device collects and how they can view and share this data themselves.

You must therefore always have this information available. We offer a template below that you can use for this purpose. Using this template is not mandatory, but it can help you meet the requirements quickly and easily. Of course, you can also upload a document from the manufacturer with the necessary information. From August 12, 2025, you can do this via your seller account.

To comply with the Data Act, you must legally provide the following information:

• The type, format, and volume of data that the item can generate.
• Whether the item can generate data continuously and in real-time.
• Whether the item stores data on the device itself or on an external server (including the retention period).
• How the user can consult, request, or delete the data, including the method, terms of use, and quality of service.

• Check if you sell connected items; these collect data and/or work with an app.
• Ask the manufacturer what data the item collects and how customers can view it.
• From the end of December 2025, when uploading new electronics product range, we will ask if your items collect data. If ‘yes’, you are obliged to upload the requested content. Your items will only go online once that information has been added. Since August 12, 2025, you can already upload the requested information as a document via your seller account. Use the template or have the manufacturer provide their own document.
• For a (small) part of the product range, it states that it is ‘optional’ to add the content. In that case, it is legally mandatory, but bol does not actively enforce it (yet). However, it is important to do so, because the supervisor can still request us to take action.

The Netherlands Authority for Consumers and Markets (ACM) will monitor compliance with the law from September 12, 2025. In case of complaints, they can contact you or bol and ask to take items offline. From April 1, 2026, bol will also enforce: in case of missing content, we will take items offline (in phases).

You are responsible for complying with the EU Data Act. We help you with tools and information, but this text is not legal advice.

Do you have substantive questions regarding this information? We recommend contacting a legal advisory firm. Partnerservice cannot help you further with this, as it concerns legislation from the European Union.

You can find the explanation from the European Union here.
You can find the explanation from the ACM as a supervisor here.