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Recently, the full text of the European Union's Data Act was officially released. This regulation, known as the "milestone of the data economy", was officially implemented on September 12, 2025, aiming to completely break the data monopoly and return the control of data from manufacturers to users.

This article will give you a clear understanding of which manufacturers and equipment the bill is legally binding.

1. Core goal: Your data, you decide

The underlying principle of the Act is unusually clear: ownership and right to use the data generated by your use of smart devices should belong to you, not the device manufacturer.

This means that you have the right to obtain, use and authorize third parties to use the data generated by your device, so as to promote more innovative services, such as energy efficiency management, predictive maintenance, etc.

2. Key targets: Who are the "manufacturers" who must comply with regulations?

The bill sets out clear compliance requirements for "data holders" and "manufacturers". The following categories of manufacturers are the focus of the Bill:

1. Manufacturers of networked products

All businesses that produce and will sell connected products in the EU market, regardless of whether they are registered in the EU.

Examples: smart appliance brands (such as Haier and Midea), smart car manufacturers (such as Tesla and Biadi), and industrial equipment manufacturers (such as Simon and KUKA).

2. Relevant service providers

Enterprises that provide digital services (such as software and cloud services) that are closely tied to the functionality of connected products. Without this service, one or more of the key features of the product cannot be implemented.

Examples: operating system and content platform providers for smart TVs, cloud control platforms for smart homes, and remote operation and maintenance software service providers for industrial machinery.

3. Data processing service providers (such as cloud service providers)

Enterprises that provide cloud services (IaaS, PaaS, SaaS), edge computing and other services must ensure that customers can freely migrate data to other service providers.

Examples: Amazon AWS, Microsoft Azure, Google Cloud, Alibaba Cloud, etc., and various SaaS software providers.

Important exemptions:

Micro and small enterprises are exempt from some obligations under Chapter II (B2C/B2B data sharing) under certain conditions, provided that they do not have non-compliant large enterprises as partners or affiliates.

3. Comprehensive coverage: Which equipment is included in supervision?

The jurisdiction of the Act is so broad that it covers almost all physical objects that can be connected to the network and generate data.

The types of equipment that must be compliant include, but are not limited to:

· Smart consumer electronics

Smartphones, tablets, laptops

Smart TV, smart music box, smart home appliances (refrigerator, air conditioner, washing machine)

Wearable devices (smart watches, fitness bracelets)

· Smart home and security equipment

Smart thermostat, smart lighting system

Smart door locks, security cameras, sensors

· Outbound tools

Intelligent connected vehicles, electric vehicles

Intelligent self-driving cars, electric scooters

Aircraft and ships with connectivity (for those operating in the EU)

· Health and medical equipment

Internet-connected pacemakers, insulin pumps and other medical equipment

Home health monitors (blood pressure meter, blood glucose meter)

· Industrial and commercial equipment

Industrial Internet of Things (IIoT) equipment: machine tools, robots, sensors

Commercial equipment: smart vending machines, networked agricultural machinery (e.g. smart tractors)

Public infrastructure: smart meters, environmental monitoring equipment (air quality sensors)

Key definition: A "connected product" in the Act refers to a device whose primary function is not to store, process or transmit data for the manufacturer or other third party. This means that products with user functions as the core, such as smart phones and smart TVs, are also within the jurisdiction, while dedicated data servers do not belong to this category.

4. Core obligations of manufacturers: What must they do?

In the face of the bill, relevant manufacturers must act immediately and complete the compliance transformation before September 2025.

1. Design compliance (top priority)

Products must default to a structured, universal, machine-readable format that allows users to access data easily, securely, and for free. This requires data accessibility to be embedded at the product design stage.

2. Information transparency

Before selling, users must be clearly informed of what data the device can generate, the format and magnitude of the data, and how users can access this data.

3. Provide a data interface

Standardized API interfaces must be established so that users or third parties authorized by users can smoothly obtain data.

4. Support data migration (for cloud service providers)

Technical, commercial and contractual barriers must be removed, customers should be allowed to switch service providers freely, and data migration fees will be phased out (completely banned after January 2027).

Summary and early warning:

For manufacturers, this is not only a compliance challenge, but also a strategic opportunity. Enterprises deployed in advance will be able to:

Win the trust of EU users and enhance brand reputation.

Leverage data liquidity to create new business models and service revenue.

Avoid the risk of products being removed from the EU market after September 2025.

The countdown to the effectiveness of the bill has entered. Relevant vendors shall immediately initiate:

1. Product line inventory: Determine which products need compliance.

2. Technical architecture evaluation: Does the existing system support convenient data export?

3. Amendments to legal provisions: Update the User Agreement and Terms of Service.

The rules of the game in the data economy have changed, and it is a foregone conclusion to move from "data exclusivity" to "data sharing". Only companies that proactively adapt to this change can take the lead in future global competition.

DISCLAIMER

This article is only a summary of the interpretation of the EU Data Act and does not constitute any legal advice. For specific compliance operations, please refer to the full text of the regulations and consult professional legal advisers.