The adoption of the EU Digital Services Act (DSA) in November 2021 represents a decisive step in redefining the responsibilities of online marketplaces, platforms, and intermediaries operating within the European Union. Set to take effect in February 2022, the DSA aims to create a safer digital environment by strengthening transparency obligations and clarifying liability for the sale of illegal or unsafe goods. For supply chain managers and platform hosts, the new regime introduces both challenges and opportunities in managing product authenticity and vendor accountability.
At its core, the DSA establishes a harmonised framework that requires online platforms to act more proactively in preventing the dissemination of illegal content and goods. Crucially for supply chain transparency, this means that platforms must now implement measures that go beyond passive hosting—they must actively ensure that sellers of high-risk goods (such as electronics, medical devices, toys, and cosmetics) are verified and that their products meet EU safety and compliance standards. Failure to do so could expose platforms to both regulatory penalties and civil liability.
A central feature of the DSA’s transparency mandate is the requirement for platforms to provide clear information to users about who is selling a given product and what steps the platform has taken to verify that seller’s legitimacy. For high-risk goods, this expectation translates into a need for seller-level certification and data traceability. One practical pathway is the integration of open-data certificates of authenticity, issued by recognised bodies or regulatory agencies, into the platform’s onboarding and product listing workflows. These certificates—such as CE marks for electronics or notified-body approvals for medical devices—should be linked directly to individual listings in a manner that is accessible and verifiable by consumers.
To operationalise this, platform hosts should work toward embedding certificate validation APIs within their seller registration systems. For example, a marketplace hosting vendors of consumer electronics could build an API connection to the EU’s NANDO (New Approach Notified and Designated Organisations) database, enabling automated checks that a seller’s claims about conformity assessments are valid. Similarly, for medical devices, integration with EUDAMED (European Database on Medical Devices) open modules could provide direct confirmation of product registration and certification status. These open-data linkages serve a dual purpose: they enhance consumer trust while also protecting platforms from liability by demonstrating good-faith compliance with the DSA’s due diligence expectations.
Yet, integrating these open-data checks is only part of the equation. The DSA also requires platforms to establish clear procedures for the removal of illegal goods and to report regularly on their content moderation efforts. This places new demands on platform operators to design takedown workflows that are both robust and scalable. The most effective approach involves building automated takedown systems powered by sandboxed APIs. These systems should be capable of flagging listings that lack valid certifications, responding dynamically to external alerts from regulators or consumer protection agencies, and triggering swift delisting where necessary.
A well-designed takedown and due diligence workflow typically begins with a pre-listing validation stage, where sellers upload product details, certifications, and compliance declarations. The platform’s backend system—linked via API to relevant regulatory databases—can then verify the data before allowing the listing to go live. Once live, the listing should remain subject to periodic automated scans, checking for expired certifications, changes in regulatory status, or external notices indicating non-compliance. Where an issue is detected, the system should initiate a graduated response: first, flagging the seller and requesting corrective action; second, suspending the listing if no action is taken; and finally, reporting the breach to competent authorities where required.
Building these systems is not without complexity. Platforms will need to invest in technology capable of interfacing securely with external data sources, while also ensuring that seller data is processed in compliance with GDPR and other data protection laws. The architecture of these solutions should prioritise modularity and security—using sandboxed APIs ensures that sensitive external systems are insulated from potential interference, while also enabling future expansion to new data sources as regulatory requirements evolve.
In practical terms, platform operators should consider the following priorities in implementing DSA-aligned workflows. First, map all product categories offered on the platform against DSA high-risk designations, and identify where certification checks are mandatory or advisable. Second, establish API connections or data-sharing agreements with relevant open registries, such as CE mark directories, EUDAMED modules, or national market surveillance authorities. Third, work with technology partners or internal development teams to design sandboxed API gateways that manage certificate validation, takedown triggers, and reporting flows. Fourth, train compliance and customer-service teams on the new processes to ensure that manual interventions (where needed) are swift and aligned with the DSA’s procedural fairness requirements.
Finally, platform operators should not overlook the value of transparency reporting. The DSA obliges very large online platforms (VLOPs) to publish detailed reports on their content moderation, takedown actions, and due diligence efforts. Even for smaller platforms, adopting this practice can enhance reputation and demonstrate a commitment to safety and compliance. Reporting templates should capture key metrics: the number of seller verifications conducted, the proportion of high-risk listings subjected to certification checks, the volume of takedowns, and the nature of external notices received. Over time, this data will not only serve regulatory purposes but also provide valuable insights into supply chain risk trends and areas where further due diligence is required.
The DSA sets a higher bar for accountability in digital marketplaces, compelling platform hosts to move beyond reactive content moderation and toward proactive supply chain transparency. By leveraging open data, sandboxed technologies, and clear governance protocols, platforms can meet these obligations while strengthening consumer confidence and resilience across their ecosystems. The challenge is substantial, but so too is the opportunity to lead in a new era of responsible digital commerce.