One access-layer pattern for any connected product

Start with this general pattern regardless — catalog, entitlement, export, third-party sharing, audit — and layer in product-specific rules where a category has its own scoping questions (a trade secret that's obviously algorithmic, a security-sensitive field like a lock credential, an overlapping sector regulation). If your product category has enough of those specifics to matter, that's the signal to build a dedicated profile on top of the general layer, not to replace it.

Broad. The Data Act defines a connected product as an item that obtains, generates or collects data concerning its use or environment and can communicate that data via an electronic communications service, physical connection or on-device access, and whose primary function isn't storing, processing or transmitting data on behalf of another party. That covers most physical products with any data connectivity, well beyond obvious 'smart device' categories.

Yes. The obligation is about whether the product generates data that's readily available or can be made available without disproportionate effort, not about whether there's a consumer-facing app. A product with only a manufacturer-side telemetry feed and no end-user app can still owe an access-on-request duty to its user.

One shared access layer with per-category scoping profiles, almost always. The catalog, entitlement engine, third-party grant model and audit log are the same architecture regardless of product category — what changes is the field list, the typical user role, and any category-specific trade-secret or safety carve-outs. Building N separate systems multiplies maintenance cost for no compliance benefit.

Potentially, yes. Chapter II generally does not apply to data from connected products manufactured, designed or provided by a qualifying micro or small enterprise, though the exception is conditional — it doesn't apply where a non-qualifying partner or linked enterprise exists, or where the small company is subcontracted to manufacture, design or provide the product or service. Document the enterprise-size assessment rather than assuming headcount alone settles it.

If your product falls into one of our dedicated categories — industrial machinery, HVAC, smart appliances, EV charging, and others linked below — start there; the scoping questions and typical field lists are already worked out for that category. Use this general page as the blueprint when your product doesn't fit an existing dedicated page, or when you're building one shared access layer across several product lines at once.