CEMA Q&A on the EU Data Act

CEMA releases expert Q&A to guide the agricultural machinery sector through the EU Data Act

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The European Agricultural Machinery Association is proud to present the CEMA Q&A on the Data Act (Version 1.1), a new resource designed to support agricultural machinery manufacturers in navigating the European Union's Data Act.

It is a living document that will be updated as new questions and legislative clarifications arise — a resource that grows with the sector's needs. Developed through extensive consultation with industry experts, the Q&A addresses the practical realities of Data Act implementation within our sector. It reflects the collective knowledge of CEMA’s member companies and their legal, technical, and regulatory specialists. The goal is to provide actionable guidance to help the industry implement this complex legislation effectively and in a way that adds value to both manufacturers and users of agricultural machinery.

The Q&A does not replace the legal text of the regulation. Final responsibility for the implementation of the Data Act rests with manufacturers.

Purpose of the document

This Q&A is more than a compliance tool — it's a bridge between regulation and implementation. It is specifically tailored to:

• Assist implementation managers and engineers working within the agricultural machinery space.
• Offer a practical interpretation of the Data Act's provisions with respect to real-world use cases.
• Serve as a supplement to official resources — not a replacement — by providing industry-specific clarity on key issues.

Topics Covered

The document touches on a broad range of legal, technical, and operational subjects, including:

1. General Applicability — Clarifying definitions of users, data holders, and recipients; timeline of obligations; and the boundaries of compliance.
2. Data and Scope — Understanding what counts as in-scope data (e.g., raw vs. processed), how connected products are defined, and what triggers data-sharing obligations.
3. Data Sharing Requirements — Outlining who must share data, under what circumstances, and through which platforms or interfaces.
4. Internal Data Usage — Explaining manufacturers' rights and responsibilities in using their own product data, including for R&D or AI development.
5. IP and Trade Secrets Protection — Strategies for protecting proprietary data and understanding where legal exemptions apply.
6. Suppliers & Dealers — The role of OEMs, suppliers, and independent repairers in data access and responsibility chains.
7. Farming Use Cases — Implications for contractors, farmers, and data ownership in agricultural fieldwork.
8. Government and Legal Requests — What happens in cases of regulatory requests, law enforcement, or exceptional need scenarios.

 Download the CEMA Q&A on the Data Act CEMA Q&A on the Data Act

***Now available in Spanish, too!***

Download Preguntas y Respuestas de CEMA sobre el Reglamento de Datos