New European legislation: provide insight into data from connected items
As an entrepreneur, your main focus is selling your items. However, legislation sometimes requires extra steps. From September 12, 2025, the European Data Act (EU Data Act) will apply. This European legislation obliges you to inform customers in advance about the data collected by connected items, such as smart devices. For example, consider 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 responsible for providing this information yourself. We will help you get started with an explanation and a convenient upload option.
What is the EU Data Act?
The EU Data Act is a new European law focused on data sharing. It applies to data collected by connected items—such as smart devices with an internet connection. The goal of the EU Data Act is to make this type of data more accessible to users, including your customers, giving them greater insight and control over the information their devices generate.
What does this mean for you?
Do you sell connected items? Then you will soon 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. 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.
What information is involved?
To comply with the EU Data Act, you are legally required to provide the following information:
- The type, format, and volume of data 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, retrieve, or delete the data, including the method, terms of use, and quality of service.
The most important action points at a glance:
- 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 products, we will actively ask whether your items collect data. If you answer “yes”, you are required to upload the requested product information. Your items will only be published online once this information has been added. Bol made it possible to upload this information as a document via your seller account since 12 August 2025. You can use the template or have the manufacturer provide their own document.
- For a (small) part of the range, it is stated that adding the product information is ‘optional’. In that case, it is legally required, but bol does not (yet) actively enforce this. Even then, it is important to do so, because the regulatory authority can still request bol to take action.
Enforcement
From 12 September 2025, the Netherlands Authority for Consumers and Markets (ACM) monitors compliance with the law. If complaints are received, they may contact you or bol and request that items be taken offline. From 1 April 2026, bol will also enforce compliance. If product information is missing, we will take items offline (in phases).
Your own responsibility
You are responsible for complying with the EU Data Act yourself. We help you with tools and information, but this text is not legal advice.
Do you have substantive questions regarding this information? Then we recommend contacting a legal advisory firm. Partnerservice cannot assist 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 supervisor here.
Frequently asked questions
Why am I obliged to do this?
The EU Data Act explicitly mentions ‘seller’, ‘rentor’ or ‘lessor’. They must share this product information prior to the sale. This means that as a seller via bol, you are also obliged to share this information.
What happens if I don't do this?
As a seller, you are legally obliged to inform customers about their purchase in advance. From 12 September 2025, the Netherlands Authority for Consumers and Markets (ACM) will check whether the law is being complied with. In the event of complaints, they may contact you or bol. From 1 April 2026, bol will also enforce the law. If product information is missing, we will take items offline (in phases).
But the manufacturer don't want to share this with customers/this is a trade secret. What now?
In special cases, a manufacturer may choose not to share this data with customers, for example if it constitutes trade secrets. In that case, you must proactively report this to the ACM. The full explanation from the ACM as supervisory authority can be found here.