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Cross-Border

Amazon Rules: US vs. EU vs. UK Requirements

Selling on Amazon's US marketplace requires CPCs, FCC IDs, and Prop 65 warnings. Selling on Amazon's EU marketplaces (Germany, France, Italy, Spain, Netherlands, and others) requires CE Declarations of Conformity, REACH SVHC communication, and WEEE registration. Selling on Amazon's UK marketplace requires UKCA Declarations of Conformity, UK REACH compliance, and UK-specific WEEE registration. Three marketplaces, three sets of compliance documentation, one Seller Central account — and Amazon's enforcement systems in each marketplace operate independently.

This guide compares Amazon compliance requirements across the US, EU, and UK marketplaces and shows how to manage multi-marketplace compliance without losing listings to documentation requests.

Not sure what each Amazon marketplace requires for your product category? Use the Sustalium Global Compliance Map — select your product type and compare the US, EU, and UK frameworks that Amazon enforces in each marketplace.

Cosmetics Regulation: US, EU, and UK Compared

Cosmetics regulation in the United States, the European Union, and the United Kingdom operates on three different legal frameworks — and a cosmetic product sold in all three markets needs three different safety assessments, three different product notifications, and potentially three different labels. The US system under MoCRA emphasizes manufacturer self-declaration of safety. The EU system requires a formal Cosmetic Product Safety Report by a qualified safety assessor. The UK system, post-Brexit, mirrors the EU structure but with separate notification, separate responsible person requirements, and the UK's own scientific advisory function.

This guide compares cosmetics compliance across all three markets and shows how to build multi-market compliance from the same toxicological data and the same product formulation.

Not sure which cosmetics regulations apply in which market? Use the Sustalium Global Compliance Map — select Cosmetics and switch between the US, EU, and UK to see MoCRA, CPSR, and UK notification requirements side by side.

Electronics: FCC vs. CE vs. UKCA Compared

Electronics is the product category with the most regulatory diversity across the three major Western markets. The US requires FCC and UL. The EU requires CE Marking under the EMC Directive, the Low Voltage Directive (or Radio Equipment Directive for wireless devices), and RoHS substance restrictions. The UK requires UKCA marking — which, for electronics, uses the same technical standards as the EU but requires separate conformity assessment and documentation. And an FCC test report is not valid for CE Marking. A CE Declaration of Conformity is not valid for UKCA.

This guide compares electronics compliance across the US, EU, and UK, and explains how to build multi-market compliance from a single test program and a single set of product data.

Not sure which EMC, safety, and substance regulations apply where? Use the Sustalium Global Compliance Map — select Electronics and toggle between markets to see FCC, CE, and UKCA requirements side by side.

Toy Safety: US ASTM vs. EU EN 71 vs. UK Standards

A toy sold in all three major Western markets must comply with ASTM F963 in the United States, EN 71 in the European Union, and the UK's designated standards (currently BS EN 71) in Great Britain. Three different testing standards, three separate certificates, and different chemical limits in each market. The most expensive compliance mistake in the toy industry is designing and manufacturing for one market and then discovering — after inventory is produced — that the product cannot legally be sold in the other two.

This guide compares toy compliance across the US, EU, and UK and explains how to build multi-market compliance from a single test program.

Not sure which toy safety standards apply in each market? Use the Sustalium Global Compliance Map — select Toys and compare the US, EU, and UK frameworks at a glance.

Clothing Rules by Market: US, EU, and UK Compared

A clothing brand that sells in the United States, the European Union, and the United Kingdom must navigate three separate regulatory frameworks for what is fundamentally the same product. The US requires a flammability certificate and FTC labeling. The EU requires REACH SVHC communication and GPSR compliance. The UK — since Brexit — requires its own UKCA marking and separate chemical compliance documentation. None of these frameworks accept the others' certificates.

This guide compares apparel compliance across all three markets and explains how to manage it without tripling your regulatory overhead.

Not sure which apparel regulations apply in which market? Use the Sustalium Global Compliance Map — select Apparel and switch between the US, EU, and UK to see every framework side by side.

Food Compliance: US vs. EU vs. UK at a Glance

Selling food in one market is a regulatory challenge. Selling the same food product in the United States, the European Union, and the United Kingdom — as many e-commerce brands do when they scale from domestic to international — means complying with three regulatory frameworks that share similar goals but differ significantly in their implementation. Your FDA-compliant food label is not valid in the EU. Your EU food contact packaging declaration is not accepted by the FDA. And since Brexit, the UK is a separate regulatory jurisdiction with its own rules.

This guide compares the food safety, labeling, and packaging requirements across all three markets and shows how to manage multi-market food compliance without maintaining three separate compliance programs.

Not sure which food regulations apply in which market? Use the Sustalium Global Compliance Map — select Food and toggle between the US, EU, and UK to see the regulatory differences side by side.