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Governance & Trade

GDPR Compliance for Manufacturers: A Practical Guide

In June 2026, the UK's Information Commissioner's Office announced a formal probe into how smart TV manufacturers use consumer data and published final guidance on IoT products, warning that most IoT data processing "is likely to result in a high risk." The same month, Italy's antitrust authority opened proceedings against Vorwerk over the shutdown of cloud services for Neato robot vacuums — a landmark case examining whether manufacturers can devalue connected products through service termination.

Product manufacturers consistently tell us GDPR is a "tech company problem." Then we show them the connected product they're shipping — the one collecting sensor data and communicating with a smartphone app — and it clicks.

If your company places products on the EU market, you are almost certainly processing personal data in ways that trigger the General Data Protection Regulation (GDPR). Connected devices, supplier records, employee data — all of it counts. On the Sustalium platform, we handle GDPR declarations for IoT manufacturers, industrial equipment makers, and consumer goods companies. Here is what actually applies to product businesses.

CBAM Certificates: Costs, Purchasing & Deadlines

With the definitive phase of the Carbon Border Adjustment Mechanism (CBAM) now in full force, EU compliance is no longer just a regulatory reporting exercise for the sustainability department. It has become a critical liquidity and treasury management issue for the Chief Financial Officer (CFO).

Importers of covered goods must now purchase, hold, and surrender CBAM certificates that directly correspond to the greenhouse gas (GHG) emissions embedded in their imported products. These certificates introduce a fluctuating, carbon-linked cost variable into your global supply chain.

To protect your profit margins and ensure uninterrupted customs clearance, you must master the mechanics of EU CBAM Declarations and the lifecycle of the CBAM certificate.

Swissness Compliance: Verify "Swiss Made" Claims

The Swiss cross is one of the most powerful brand assets in the global marketplace. Studies consistently demonstrate that consumers are willing to pay a 20% to 50% price premium for products bearing the "Swiss Made" designation, particularly in luxury goods, watchmaking, cosmetics, and agricultural products.

Because of this immense commercial value, the Swiss government aggressively protects its national brand. Under the "Swissness" legislation (in force since 2017), claiming Swiss origin is subject to strict, quantified cost-accounting thresholds.

Misusing the Swiss cross or "Made in Switzerland" label is a criminal offense, exposing brands to prosecution by the Swiss Federal Institute of Intellectual Property (IPI), seizure of inventory at customs, and devastating civil damage lawsuits from competitors.

To legally claim "Swiss Made" status, you must prove your compliance through rigorous, auditable calculations. Here is how to navigate the Swissness cost-accounting rules.

Country of Origin & Material Declarations

In the modern global trading system, a product's physical journey is rarely simple. A company might design a product in Europe, source raw materials from South America, manufacture components in China, and conduct final assembly in the United States.

Because of this complex geographic fragmentation, customs authorities, tax agencies, and enterprise buyers require strict verification of Country of Origin (CoO) and Material Declarations.

These are not optional documents. Proving origin is a critical legal requirement for: * Tariff Calculation: Determining if your goods qualify for preferential lower tariff rates under free trade agreements (like EU-UK TCA or USMCA). * Trade Restrictions: Ensuring your goods do not violate trade bans, anti-dumping duties, or sanctions (such as restrictions on specific Russian metal imports or Xinjiang region raw materials). * Supplier Risk Management: Enterprise buyers require a complete material breakdown to ensure compliance with human rights and environmental regulations like CS3D.

If your customs paperwork contains a generic, unverified origin claim, your shipments can be detained at borders, exposing your company to severe delayed-shipment penalties and tax-evasion investigations. Here is how to calculate, document, and declare your supply chain provenance.