9. What happens if a connected product that is placed on the EU market generates data when it is used abroad?

If a connected product is placed on the market in the EU and then used outside the EU, the data generated by that connected product both inside and outside the EU should be made available to the user in accordance with the Data Act. As explained in the answer to Question 6, a connected product falls within the scope of the Data Act if it has been placed on the market in the EU. This means that ‘mobile’ connected products (e.g. ships, airplanes, trains, and cars) should be treated in the same manner as other connected products. The mere circulation of a ship, airplane, train, or car on EU territory or in EU waters is not sufficient for a connected product to be considered as having been ‘placed on the EU market’ because there has been no transfer of ownership. The rules of the Data Act build on civil law relations of ownership and lease between a person or entity and an object. The fact that connected products such as cars, rail vehicles or planes are registered in a Member State is an indicator that the connected product in question was placed on the EU market.