GPSR data model
Manufacturer, EU responsible person, warnings and safety instructions in every language; manufacturers as separate records, so one address change is one fix, not thousands.
Product data and EU rules.
Product data and PIM ready for GPSR, the product passport, green claims, the AI Act and NIS-2.
Which rules
Five EU laws affect your product data and the systems that hold it.
Each one asks for something different, but all come down to the same thing: the right data must be in the system, correct in every language and sent to the right sales channels. That is why we start with the PIM. We are not a law firm; a lawyer decides which rules apply to you, and we make the data meet them.
- GPSR: manufacturer, EU responsible person and warnings in every online offer.
- Digital product passport (ESPR): product data behind a QR code, group by group.
- Greenwashing rules (ECGT): no generic "eco" claims without proof.
- AI Act, Article 50: transparency for chatbots and AI-generated content.
- NIS-2: secure systems where product data lives.
Dates in the EU rules
The EU dates your product data has to meet.
Dates from the official texts on EUR-Lex. National dates for directives can differ.
- Dec 2024GPSR applies from 13 December
- Mar 2026national green-claims laws due by 27 March
- Jul 2026EU product passport registry due by 19 July
- Sep 2026green-claims rules apply from 27 September
- Sep 2026guarantee notice and label from 27 September
- Per grouppassport duties, one delegated act each
- Checks in the PIMflag AI content and unproven green claims before publishing
- Not a law firmyour lawyer decides which rules apply, we make the data meet them
Sources: EUR-Lex, Regulation (EU) 2023/988 art. 52 · Directive (EU) 2024/825 art. 4 · Regulation (EU) 2024/1781 art. 13 · Implementing Regulation (EU) 2025/1960 art. 3; checked 4 Nov 2026
Digital product passport
Five steps to DPP readiness.
A passport is not an IT project you can buy. It is the result of well-run product data.
Data audit and roadmap
Find where passport data lives, who owns it and what is missing.
One source in PIM or MDM
Centralise product data in Pimcore or Akeneo instead of a separate DPP silo.
- Supplier portal
Supplier data onboarding
Suppliers submit structured, validated data themselves, not by e-mail and spreadsheets.
Passport architecture
The PIM at the core, with a passport generator, the EU registry connector and APIs.
Data governance
Clear roles and approval workflows, from product manager to compliance officer.
In one table
Regulations and product data in one table.
Dates as of 24 October 2026. National dates for directives differ by country.
| Regulation | Applies from | What it requires from data | What we do in the PIM |
|---|---|---|---|
| GPSR (Regulation 2023/988) | 13 December 2024 | Manufacturer with postal and electronic address, EU responsible person, product identification, warnings in the local language | GPSR data model in every language, sent to the shop and marketplaces |
| Digital product passport (ESPR 2024/1781) | Registry by 19 July 2026; obligations per delegated act | Data set out in the delegated act for the product group, accessible through a data carrier such as a QR code | Data model for the passport and a public passport page behind a QR code |
| Greenwashing (Directive 2024/825) | EU: 27 September 2026; Poland: 27 September 2027 | Environmental claims only with proof; durability, update, repair and spare-part information | Checks catch unproven claims in all languages and channels and block publishing until approved |
| Guarantee label (Implementing Regulation 2025/1960) | 27 September 2026 | A harmonised notice on the legal guarantee, and a label when the producer offers a commercial guarantee of durability | Guarantee fields per product and language, with the notice and label sent to the shop |
| AI Act, Article 50 (Regulation 2024/1689) | 2 August 2026 | Transparency for chatbots, deepfakes and generative AI output | AI-changed fields marked, human approval, change history, AI text detection, labels in the shop |
| NIS-2 (Directive 2022/2555) | National laws; Poland: 3 April 2026 | Secure systems: risk management, monitoring, continuity, ICT supply chain | Secure infrastructure, audit and remediation plan, documentation, supplier review |
Sources: EU regulations and directives as listed; national dates from the Polish implementing acts. As of 24 October 2026.
Which data is missing in your PIM?
With your lawyer's list of rules, we check your product data and show what to add first.
Scope
What we build in the PIM.
Digital product passport
An attribute, document and relation model that grows with each delegated act, and a public passport page behind a QR code fed from the PIM.
Claim checks
Automated checks that catch unproven environmental claims, look for a matching certificate and block publishing until someone approves.
AI content control
AI-changed fields marked, human approval before publishing, a full change history and labels for AI content in the shop.
Secure systems
Backups, monitoring, updates and access control for the PIM and shop, with an audit, documentation and supplier review.
Supplier data
Passport and safety data collected from supplier PDFs and spreadsheets with openProd, using classifications such as ETIM.
How we work
From a data audit to rules that keep working.
- 01
Data audit
With your lawyer or compliance team we agree which rules apply to your products and markets, then check what is missing, misplaced or duplicated.
ResultA list of rules and data gaps. - 02
Attribute model
Attributes, dictionaries and relations for GPSR, the passport, environmental claims and AI history, in Pimcore, Akeneo or Ergonode.
ResultCompliance attributes in your PIM. - 03
Checks and publishing
Rules and workflows catch gaps and risky content before publishing, and data goes to the shop, marketplaces and passport page.
ResultGaps caught before publishing. - 04
Upkeep
Systems kept secure, and the data model extended as new delegated acts and channel requirements appear.
ResultA data model that follows new rules.
Case studies
Structured product data in practice.
These are product data projects, not compliance projects: they show the structured data that compliance work builds on.
Automated catalogues
Marcopol
A solution integrated with Pimcore that automates the ToolsWorld catalogue, safety data sheets and declarations of conformity from central product data.
Read case study
ETIM / BMEcat mapping
GTV
A central Pimcore system extended with ETIM classification, BMEcat export and the ETIM Mapper tool.
Read case study
PIM, DAM and e-commerce hub
Ceramika Paradyż
A central hub for product data and presentation, built on Pimcore.
Read case studyFAQ
Questions about product data compliance.
Are you a law firm?
No. A lawyer or your compliance team decides which regulations apply to your company and products. We prepare the data and systems so the requirements from that assessment can be met, checked and maintained.
What does GPSR require in an online offer?
Under Article 19 of Regulation (EU) 2023/988, applicable since 13 December 2024, an online offer for a consumer product must show the manufacturer's name and postal and electronic address, the responsible person in the EU if the manufacturer is outside the EU, product identification such as a picture and type, and warnings and safety information in the language of the country where it is sold.
When does the digital product passport become mandatory?
Product group by product group. The ESPR (Regulation (EU) 2024/1781) applies from 18 July 2024, and the Commission had to set up the passport registry by 19 July 2026, but the obligation for a group starts only with a delegated act for it, and applies at the earliest 18 months after that act enters into force. The Commission's indicative plan puts the act for iron and steel first, in Q4 2026, then textiles, tyres and aluminium in 2027. The battery passport (Regulation (EU) 2023/1542) applies from 18 February 2027 for LMT batteries, industrial batteries over 2 kWh and EV batteries. More in PXM and regulatory compliance.
What changes with the greenwashing rules?
Directive (EU) 2024/825 bans generic environmental claims such as "eco-friendly" without proof, and claims about a whole product that apply to one feature. The directive requires member states to apply it from 27 September 2026, but national laws differ: Poland's implementing act (Journal of Laws 2026, item 1353) enters into force on 27 September 2027. If you sell in other EU countries, check the date there with a lawyer.
Does the AI Act require labelling AI product descriptions?
Article 50, applicable from 2 August 2026, does not name product descriptions directly. It covers chatbots, which must tell customers they are talking to AI, machine-readable marking of generative AI output by providers, deepfakes, and AI text published on matters of public interest unless a human reviewed it and takes editorial responsibility. For generative systems placed on the market before 2 August 2026, the marking deadline is 2 December 2026 (Regulation (EU) 2026/1744). See also AI-generated content and SEO.
Does NIS-2 apply to PIM and e-commerce systems?
If your company is an essential or important entity under your country's NIS-2 law, the systems where product data lives, such as the PIM, the shop and integrations, fall under its risk management. If we maintain those systems, we are part of your ICT supply chain. In Poland the amended National Cybersecurity System Act applies from 3 April 2026; entities in scope must meet the obligations by 3 April 2027, and essential entities complete their first audit by 3 April 2028.
Which PIM do you do this on?
Where do we start?
With a data audit. We check which data required by GPSR, the digital product passport and the rules on environmental claims you already have, where it is and what is missing. The result is a list of gaps and a plan: the attribute model, automated checks and publishing to channels.
Olgierd MrozikCEO, LemonMind
Not sure where to start?
Let's check which compliance data you already have.
In a free consultation we check which data is already in your PIM, what is missing and what can be checked automatically.
30 minutes. Google Calendar opens in a new tab.
- 2010 founded
- 300+ projects
- 70+ PIM and e-commerce implementations