The same duty, several markets
Cross-market regulatory questions fail when they are answered as eight separate memos. How to ask for the differences that actually change the work.
A product that moves is a legal object in every place it lands. The question is rarely 'what is the law in country X'. The question is 'where does country X diverge from the rule I already understand, and does that divergence change a duty, a deadline, a language, a threshold or a named person'.
Teams burn weeks producing eight parallel memos that each restate the common core. The useful artefact is shorter: a list of differences, each pinned to a text, with the shared baseline stated once.
Name the duty before you name the countries
If you start with geography you will get geography. 'Tell me about labelling in these markets' invites a tour. 'Who is the duty-holder for the notification in Article Y, and does any of these markets assign it differently' invites a comparison. The second question can be answered. The first one can only be surveyed.
Write the duty in one sentence, in the language of the instrument you know best. Then ask where that sentence breaks. Thresholds break. Definitions of the product break. Who counts as the person established in the territory breaks. Dates of application break. Language of the dossier breaks. Almost everything else is restatement.
Do not flatten identifiers
A UN number, a CAS number, an authorisation number and a national registration number are not substitutes for each other. Cross-market work goes wrong when a spreadsheet treats them as one column. If the join between two registers is a chemical identity, say so. If the join is a product authorisation, say so. If there is no join, that is the finding.
The same caution applies to 'harmonised'. Harmonised is a term of art in some systems and a hope in others. A classification that is harmonised in one instrument may still sit under a national list somewhere else. Cite both, or you have hidden the fork.
Read the national layer, not just the union layer
Where a regional instrument exists, people stop at it. Competent authorities do not. They keep registers, languages, fees, transitional lists and enforcement practices that the regional text does not bother to repeat. If your comparison cites only the regional regulation, you have compared the shared floor, not the work.
The opposite error is also common: treating every national page as if it invented the duty. Often the national page is an implementation of something you already cited. The trail should show the join, not a pile of URLs.
A comparison that can be checked
- State the baseline instrument and the duty in one paragraph.
- For each market, record only the delta: extra list, different duty-holder, extra language, different deadline, missing register.
- Cite the national text that creates the delta, not a summary of the whole regime.
- Mark markets where the corpus has no source. Missing is a result. Guessing is not.
That shape is what multi-market questions in RegAffairs AI are for. The corpus is 3,045 official datasets across 8 industries and 108 jurisdictions, searched together, so the comparison does not begin with eight separate subscriptions. The answer still has to be written as differences, not as a stack of country chapters.