In the coming years, the European Union will introduce a series of major regulations in which product data plays a central role. If your organization manufactures, imports, distributes, or sells physical products within the EU, these new rules will affect which data you need to gather, maintain, validate, and share. Read on to discover the most important regulations, what they demand, and how to create a strong data foundation that helps your organization stay compliant.
Please note: this blog captures our understanding as of April 2026. It is a practical overview, not legal advice. Three caveats apply:
- Delegated acts are still being drafted: specific data requirements, timelines, and technical standards remain subject to change.
- Simplification pressure is real: Omnibus I has already narrowed scope and shifted deadlines; further changes are possible.
- The direction is fixed: more product data, more transparency, more traceability. Organizations that delay risk fines, market limitations and falling behind.
Quick navigation:
- EU Product Data Compliance
- ESG & The Green Deal
- Corporate Sustainability Reporting Directive (CSRD)
- ESPR (Ecodesign for Sustainable Products Regulation) & DPP (Digital Product Passport)
- EUDR (EU Deforestation Regulation)
- PPWR (Packaging and Packaging Waste Regulation)
- GPSR (General Product Safety Regulation)
Product Data Compliance Can’t Wait
For many years, EU product regulation was relatively straightforward: a limited number of directives with modest enforcement. That period has ended.
The pace of new rule-making is accelerating, and enforcement is becoming both stricter and more comprehensive. Control no longer comes exclusively from public bodies (like the NVWA or ACM in the Netherlands), it now also can be expected from NGOs, certification bodies, auditors, banks, and even consumers.
The fundamental shift is this: compliance is no longer a paperwork exercise. Organisations must be able to actively demonstrate that their products meet requirements, using structured, verifiable, and traceable data.
Product data has consequently evolved from a commercial advantage into a legal precondition for EU market access.
On-demand webinar
Watch on-demand: “Prepare Your Product Data –
European Laws & Regulations Update”
In this 45-minute webinar, Guus van de Mond and Remco Smit will delve into the upcoming European laws & regulations in relation to product data. Learn more about all upcoming laws and regulations, how to be compliant, and what first steps to take.
ESG & The Green Deal
The roll-out of so many regulations is not coincidental. It traces back to the 2019 European Green Deal, the EU’s strategic commitment to a sustainable economy by 2050. ESG legislation is the operational instrument that converts this ambition into binding requirements.
ESG covers three dimensions:
- Environmental: a company’s climate impact, including emissions, energy use, and resource management
- Social: how employees, suppliers, customers and communities are treated, spanning labour conditions, diversity, safety, and human rights
- Governance: internal conduct covering ethics, transparency, executive remuneration, and board structure
Every regulation discussed in this document is rooted in one or more of these three pillars.
CSRD and ESRS: Reporting Obligations and Product Data Demands
The Corporate Sustainability Reporting Directive (CSRD) obliges companies to report in detail on ESG performance. It operates together with the European Sustainability Reporting Standards (ESRS) as a two-tier framework:
- CSRD = the law. Determines who must report, when, and that reports require independent assurance.
- ESRS = the standards. Prescribe what must be disclosed and in what form.
Who falls within CSRD scope?
Following Omnibus I (December 2025), the reporting population has been materially reduced:
What product data does CSRD/ESRS require?
CSRD applies at company level rather than product category level, but organizations producing or selling physical goods face the most extensive data obligations. Key examples include:
- Scope 3 greenhouse gas emissions from purchased goods and inbound logistics
- Energy consumption attributed to products
- Circularity indicators
- Substances of concern present in products
- Carbon footprint and material composition data from suppliers
Why SMEs remain affected: VSME
Even organizations outside CSRD’s legal scope are not exempt from its effects. Large companies in scope must account for their entire value chain, which means requesting sustainability data from their suppliers, the majority of whom are SMEs.
The Voluntary Sustainability Reporting Standard for SMEs (VSME) provides a standardised response framework for exactly this situation. Although participation is optional, it’s rapidly becoming the standard expectation for any supplier to a CSRD-obligated customer.
4 EU Regulations That Demand Structured Product Data
Beyond CSRD, four product-level regulations have an immediate and direct impact on product data management.
1. ESPR and the Digital Product Passport (DPP)
The Ecodesign for Sustainable Products Regulation (ESPR) is the EU’s overarching framework for sustainable product design. It applies to virtually all physical products on the EU market, with food, animal feed, and medicines excluded.
Its defining feature is the Digital Product Passport (DPP): a standardised digital record for every product, accessible via QR-code, NFC, or RFID by consumers, regulators, and recyclers. Core data fields include:
- Product identification: unique ID, GTIN, product name, and category
- Carbon footprint: full lifecycle CO₂ calculated using EU methodology
- Material composition: complete bill of materials including hazardous substance data with CAS numbers and concentrations
- Circularity and durability: repairability score, expected lifespan, recycled content, disassembly guidance
- Supply chain transparency: origin of key materials and conformity documentation
Timeline: The ESPR entered into force on 18 July 2024. DPP requirements for the first priority product groups are anticipated from 2027–2028, with wider rollout extending through 2030 and beyond. Priority sectors cover batteries, textiles and footwear, furniture, electronics and ICT equipment, iron, steel and aluminium, tyres, detergents and cosmetics, paints and coatings, and selected chemicals and plastics.
2. EUDR: EU Deforestation Regulation
The EUDR is among the most data-intensive product regulations the EU has ever enacted. It requires that goods entering or circulating within the EU can be demonstrated to be deforestation-free and legally sourced. The regulation covers products containing or derived from cattle, cocoa, coffee, palm oil, rubber, soy, or wood — including downstream products such as leather, chocolate, paper, furniture, and tyres.
Despite its environmental framing, the EUDR is fundamentally a product data challenge on four levels:
- Knowing your product composition: every SKU requires a complete bill of materials tracing each material to its origin.
- Linking SKUs to supply chain data: the required due diligence statement demands a documented chain from finished product through to the GPS coordinates of the production plot, the production date, and a deforestation risk assessment.
- Operating at scale: for a mid-sized retailer, this translates to potentially millions of data points, refreshed per consignment.
- Connecting disparate systems: product master data, bills of materials, supplier records, geolocation data, risk assessments, and declarations each reside in separate systems. A governed central data foundation is essential.
Timeline: Large operators and traders must comply from 30 December 2026; small and micro enterprises from 30 June 2027. Non-compliance risks include fines from a minimum of 4% of annual EU-wide turnover, confiscation, market bans, and criminal liability for repeated or serious breaches.
3. PPWR: Packaging and Packaging Waste Regulation
The PPWR supersedes the former Packaging Directive and imposes new requirements on all packaging placed on the EU market, irrespective of industry. Manufacturers, importers, distributors, retailers, and e-commerce operators are all in scope.
For every discrete packaging component — carton, bottle, label, closure — a technical dossier and Declaration of Conformity are required. Mandatory data includes:
- Material type and weight per component
- Inks, coatings, and adhesives used
- Post-consumer recycled content percentage, supported by supplier certification
- Recyclability class (A through E)
- Substances of concern including lead, cadmium, mercury, and PFAS
The regulation also introduces EPR fee modulation: packaging that scores well on recyclability and recycled content attracts lower producer responsibility contributions. Well-managed packaging data therefore has a direct financial benefit.
Timeline: Published in February 2025, fully binding from 12 August 2026. All packaging must be recyclable by 2030.
4. GPSR: General Product Safety Regulation
The GPSR has been in force since December 2024, replacing the previous General Product Safety Directive. It establishes the baseline safety standard for all non-food consumer products in the EU, and is the most immediately applicable regulation for most businesses.
Companies must be able to supply on demand:
- Product name, model number, and batch or serial identifier
- Manufacturer name, address, and contact information
- Multilingual safety warnings, age restrictions, and usage instructions
- Technical documentation including risk assessments, test reports, bills of materials, and substances of concern
- CE marking status
Online platforms including Amazon, Bol, and Zalando are obligated to proactively remove non-compliant listings, with immediate commercial consequences. Separately, regulators such as the NVWA may impose fines running to tens of thousands of euros per infringement.
Building a Product Data Foundation for Compliance
A common mistake is to begin with an ESG reporting tool, only to find that the underlying data infrastructure is absent. The recommended sequence is:
- Regulatory mapping: establish which regulations apply to your organisation now and within a three-year horizon.
- Attribute inventory: catalogue required data fields per regulation, identify overlaps, and group them.
- Data model extension: update your PIM, MDM, or PLM system with the additional attributes, validation rules, and version management needed.
- Data flow design: connect supplier portals, life cycle assessment tools, and external reference datasets.
- Governance assignment: allocate ownership for each attribute and establish an audit trail for regulatory purposes.
- System integration: link to CSRD reporting platforms, DPP registries, and customer-facing portals.
The central principle is that product data must be consistent, traceable, and shareable across the organisation and its value chain. Compliance has shifted from document management to data infrastructure. Governance defines and controls the data; processes maintain it; architecture structures it; and technology enables it to scale.
Key Takeaway: Structured Product Data as a Condition for Selling & Trading Products in the EU
Every regulation covered above (CSRD, ESPR/DPP, EUDR, PPWR, GPSR) shares a single common requirement: structured, reliable, and scalable product data as a condition of selling in the EU.
The trajectory is clear: from reactive and administrative, to proactive, data-driven, and actively enforced.
Organisations that wait will accumulate risks and costs. Those that invest in the right data foundation now will be positioned not only for compliance, but for commercial advantages as well!.
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