---
url: https://eurocomply.app/regulations/data-act/persona/connected-product
canonical: https://eurocomply.app/regulations/data-act/persona/connected-product
title: Data Act for Connected-Product Manufacturers — EuroComply
regulation: Data Act
regulationNumber: (EU) 2023/2854
celex: 32023R2854
persona: Connected-Product Manufacturers
personaSlug: connected-product
inForceDate: 2024-01-11
applicationDate: 2025-09-12
sourceUrl: https://eur-lex.europa.eu/eli/reg/2023/2854/oj
lastReviewed: 2026-05-12
author: EuroComply Team
license: CC-BY-4.0
---

# Data Act for Connected-Product Manufacturers

The Data Act creates user access and portability rights for the data generated by connected products. Manufacturers must design products and related services so that data is, by default, accessible to the user — easily, securely, free of charge, in a comprehensive, structured, commonly used, and machine-readable format (Article 3).

## Does Data Act apply to connected-product manufacturers?

Yes if the product is a connected product placed on the EU market, or a related service offered to users in the EU. The duty applies regardless of where the manufacturer is established.

**Key considerations:**

- Article 3: design connected products so data is accessible to the user 'by default, easily, securely, free of charge' and in a structured machine-readable format
- Article 4: where data is not directly accessible from the product, the data holder must make it available on request, free of charge, to the user
- Article 5: users have the right to share data with third parties — but trade-secret protection (Article 4(6)) and contractual safeguards apply
- Information-duty timing: pre-contract information under Article 3(2) must be provided before the user is bound by any contract for the connected product

## Underlying Data Act facts

**Full name:** Regulation (EU) 2023/2854 of the European Parliament and of the Council on harmonised rules on fair access to and use of data (Data Act).

**Maximum fine:** Where personal data is involved: GDPR Article 83 rates apply (€20M / 4%). Other breaches: set by member states..

**Key dates:**

- 2024-01-11 — Entry into force (Article 50)
- 2025-09-12 — Most provisions apply (Article 50)
- 2027-01-12 — Cloud switching charges (over and above costs incurred) must be removed (Article 29)

## Recommended next step

[Read the Data Act compliance guide](https://eurocomply.app/regulations/data-act)

## Related EuroComply resources

- Full Data Act compliance guide: [/regulations/data-act](https://eurocomply.app/regulations/data-act)
- Markdown companion: [/regulations/data-act.md](https://eurocomply.app/regulations/data-act.md)

## Source

Authoritative text: [(EU) 2023/2854 — EUR-Lex](https://eur-lex.europa.eu/eli/reg/2023/2854/oj) (OJ L, 22.12.2023).

---

Informational only. Not legal advice — consult qualified legal counsel.

Last reviewed: 2026-05-12 by the EuroComply Team. License: CC-BY-4.0.