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Products or software on the EU-market? Stricter product liability from 9 December 2026, including for importers

Products placed on the market on or after 9 December 2026 are subject to new EU product liability rules, which also cover software, apps and AI. If a defective product causes personal injury or damage to private property or private data. If the manufacturer is established outside the EU, the importer may also be liable. A defect caused by an update, or by a missing security update from the manufacturer, may also give rise to liability.Map your role in the distribution chain and review your contracts with suppliers and customers carefully to limit your liability exposure.

From 14 December 2027: EU ban on products made with forced labour

From 14 December 2027, products made wholly or partly with forced labour may no longer be sold in or exported from the EU. This applies to every business and every product, including components and raw materials.If a supervisory authority establishes that a product falls under the ban, it can order its withdrawal from the market. Map your suppliers now, including those further up the chain, and include provisions on working conditions and information obligations in new purchase contracts.

Dutch 30% ruling: partial non-resident status ends on 1 January 2027

Expats who were already benefiting from the Dutch 30% ruling at the end of 2023 have been able to opt for partial non-resident taxpayer status until the end of 2026 under transitional rules. That option will no longer be available from 1 January 2027.Under this status, expats living in the Netherlands were treated as non-residents for Box 2 (substantial shareholdings) and Box 3 (savings and investments), meaning that their foreign assets, among other things, were not taxed in the Netherlands. From 2027, they will be taxed on these assets in Box 2 and Box 3 in the same way as other Dutch residents. The 30% ruling itself remains in place. Do you employ expats in the Netherlands who benefit from the 30% ruling? Let them know in good time that this may affect their Dutch tax return for 2027, so that they can take advice.

Could you suddenly qualify as a creditor under the new European Directive?

Do you offer consumers deferred payment, payment in instalments or another form of credit? If so, the implementation of the Consumer Credit Directive II (CCD2) may have consequences for your business model and compliance obligations.CCD2 broadens the European framework for consumer credit. Buy Now, Pay Later providers and certain crowdfunding platforms, among others, will be brought within the scope of the new rules. As CCD2 is a directive, the new rules must first be implemented in Dutch legislation. For businesses, it is therefore important to assess now whether their products or services will fall under the new rules.