June 2026 'We're too small', 'we don't charge EU users', 'our vendor handles it': why these assumptions fail Intro Article 27 GDPR requires organisations without an EU establishment that offer goods or services to individuals in the EU, or monitor their behaviour, to appoint an EU Data Representative ('EU Data Rep.'). In our work with US companies, the obligation is rarely ignored deliberately. More often, it is missed because of a handful of persistent myths. Here are the fi