Enter your trader information to comply with the EU DSA

Developers can now add their required profile details to ensure continued visibility for users in the European Union (EU). Be sure to update your information before February 16th to remain compliant. This requirement still applies to any listings or plugins in the Adobe Exchange and any publicly distributed Adobe Express add-ons under the EU Digital Services Act (DSA). FAQs are available here.

Learn more: Know your trader

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I’m waiting for tomorrows event to ask some questions, which I’ve sent to ccintrev at adobe.com more than 2 days ago, but never got any reply :frowning:

@Ingo Why can we only edit trader information once, and after the second time we have to request Adobe to modify it by email?

This information is expected to change frequently and is therefore unnatural by design. Why don’t you consider it as easy to edit as the listing detail?

Hi @Karmalakas you can also share here or send me via email. Was it the problem that your marketing website field was empty? If so, that is fixed now

Hi @sttk3 this is currently required since our review team checks and approves the data. Why should trader information change frequently? I expected that business email, address or phone number normally stay the same for a long time. You can also send me via email if you prefer.

While a corporate organization may have permanent containers, for individuals, they will easily change due to changing life stages.

And in the case of Adobe Exchange/Plugin Marketplace, individuals are expected to be the main target group.

@agandhi from the Marketplace team mentioned in yesterday’s meeting that they are aiming for future changes to not require contact with Adobe every time.

I’ll just copy my email here:

When I click to submit, the loader just keeps spinning and nothing happens.

Also, I live in EU and if I don’t have a business per se, but rather a local individual license to do some commercial activities. Is there any way to not reveal my personal phone number and address? I don’t have business ones. I really wouldn’t want everyone on the internet to know where I live and how to contact me by phone :confused:

Where will this information be shown?

Also about D-U-N-S - if I’m a EU resident, do I have to have one still? I’ve read a bit and I understood it’s only for US residents, isn’t it?

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they are aiming for future changes to not require contact with Adobe every time

This is nice. It would be even better if they announced the release date as well.

Hi @Karmalakas, can you try to enter the data once more? We hade fixed some small things on the backend on Monday. Perhaps one of this was related to your spinning wheel.

As you say - you even run some commercial activities. Everyone who distributes assets, scripts or plugins on Exchange or for Express is considered a trader and therefore the EU requires those information. You could use a P.O. Box address or try to get a (free) telephone number that is not your private one that you can share.

The information will only be shown to users in the EU that click to your plugin detail page an then click once more to show the trader information. People outside the EU won’t be able to see them at all.

The DUNS number is optional. It’s an ID that is valid globally. So you can ignore that field

We don’t have a release date since we don’t know if or when this will change. But you can enter the information easily the first time and then the review team will update for you which should also not be a big issue or take too much time

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We don’t have free phone numbers. Also I’d need to figure out how to get a P.O. Box, which costs more than I sometimes sell…


So basically available to any scrape bot on the web


I think I’ll start looking into how to rewrite my plugins pirating prevention and just sell CCX directly

Why would anyone need a physical address or P.O box to sell digital goods? As if there was some return policy

There actually is.

Consumers have a 14-day cooling-off period counting from the conclusion of the contract and a guarantee of “conformance” for a minimum of two years.

Could you point exactly to the paragraph, where it describes the return process of digital goods to a PO Box or a physical address? :slight_smile: I can’t find

Refund !== Return

Ok, I took the some return policy too lightly.
The return process of durable/tangible media to a physical address is described in Article 17.

But you were mainly asking for reasons for the physical address.

Remember, I am not a lawyer, and I also hesitate to provide my address, plus unknowingly take on all trader obligations/liabilities that I never considered in a B2B business. I don’t yet even have a website required by Exchange, because I first want to get my terms etc. straight. Diligence.

Back to the question: DSA Article 30 Point 1. (a) says so, repeating UCPD Article 7 Point 4 (b) and even CRP Article 6 Point 1 (c). IMO the EU really means it.

To my understanding this is so that consumer and whatever authorities can send the trader kind “cease and desist” letters if your presence on the marketplace does not comply to some odd rule.

Look further down to DSA Article 31, if besides to a trader there is also an “economic operator” - what I understand as manufacturer/developer or importer/distributor, there should also be an address field for that. @Ingo For overseas manufacturers/developers nudged into a trader role, would the economic operator be Adobe? @agandhi do we have this separate record at all? E.g. if some distributor that makes the product available to the (EC) market, and the reseller-trader purchases from them, where can the trader place that info?

Interestingly the EU is vague on other aspects of contract law because that’s national law. But afaik the trader’s address also belongs onto the copy of the contract that is to be sent to the consumer before the download begins.

The same way as the the trader should receive details about the consumer in the technical notice about the individual contract, including plenty other parameters. That is, as soon the contract is concluded. Not two weeks later as anonymized aggregate. At least if the trader is the “final trader” - the primary contact for the consumer.

While we’re there, I also have a question. Given the role of “merchant of record” somewhere around here (unknown concept in EU regulation), which gets pretty close to “final trader”, shouldn’t their address be shown in the trader info, rather than ours? Just sayin’

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