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Trader traceability database

trader-traceability-databaseDomain: marketplace-platformType: in-house

Description

Trader traceability is the operational expression of two converging regimes: the EU's Market Surveillance Regulation 2019/1020 (which extended product-safety responsibility to economic operators including online sellers) and the DSA's Article 30 KYBC obligations (which require platforms to know who is selling on their service). The traceability database is the queryable inventory that maps each product or listing to its responsible trader, the trader's identification, the trader's address, and (for products that fall under the product-safety regimes) the economic-operator information that gives an EU-resident point of contact for product-safety enforcement. Authorities (national market-surveillance bodies, customs, the European Commission for DSA-designated platforms) have a right to query this database on demand, typically within a fixed window. The operational pieces are the data model that links listings to traders without losing the link as products are edited or republished, the query surface that authorities can use without bespoke integration work each time, and the retention policy that keeps the link available for the regulatory window even after a listing is taken down. The recurring difficulty is link stability; products that are relisted, cloned, or merged tend to lose their trader association unless the data model treats the trader-product link as first-class.

Applicability

Applies when: business model role is intermediary or mixed.

How predicates are evaluated

Required by (2 regulations)

  • DSA

    Article 31 — traceability of traders.

    Regulation (EU) 2022/2065 of the European Parliament and of the Council (Digital Services Act)

  • EU GPSR

    Article 22(7-8) — trader-information schema retained and disclosed to market-surveillance authorities on request; cooperation with authority investigations under Article 22(8).

    Regulation (EU) 2023/988

Fulfilled by (1)

  • In-house build · high effort
    Standard marketplace-platform engineering build; no off-the-shelf vendor covers the full obligation.

ClearLaunch does not accept payment from vendors. Methodology.

Evidence formats

  • traceability database schema
  • authority-query SLA dashboard

ClearLaunch provides legal information based on publicly available regulatory sources. It does not constitute legal advice and does not create an attorney-client relationship. Consult a licensed attorney in your jurisdiction before making compliance decisions.

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Built by Neel Patel, in-house game counsel. Games touch more compliance domains at once than anything else in tech. That's what ClearLaunch was designed around.

ClearLaunch provides legal information based on publicly available regulatory sources. It does not constitute legal advice and does not create an attorney-client relationship. Consult a licensed attorney in your jurisdiction before making compliance decisions. Operated by a Washington-licensed attorney. Not licensed in California or other US states. ClearLaunch provides legal information; consult a licensed attorney in your jurisdiction. Data reviewed through March 2026. Methodology

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