US vs Europe

Making, marketing and selling the same sneaker on both sides of the Atlantic

The product is the same. Almost everything around it is not: where it’s cheapest to make, what happens at the border, how the price is shown, what the customer can send back, which laws apply, and how it gets paid for. This page puts the two side by side so you can choose a primary market deliberately and plan the second as a dated phase rather than an afterthought.

A note on “Europe”: most of what follows treats the EU’s 27 members as one customs and VAT territory, which for your purposes they are. The UK left that territory in 2021 and now behaves like a third country with similar rules. Switzerland and Norway are outside the customs union too. Where it matters, they’re called out.

At a glance

United States European Union
People ~340 million, one language, one currency ~450 million, 24 official languages, the euro in most member states
Customs territory One One, but the UK, Switzerland and Norway are outside it
Tax on sales Sales tax, 45+ state regimes, shown excluding tax VAT, 17–27% by country, shown including tax
Consumer-return law None federal; your policy, clearly posted 14-day right of withdrawal on online sales; two-year conformity guarantee
Typical online fashion return rate 20–30% 25–40%; Germany often higher
Dominant payment methods Cards, PayPal, Apple Pay, Shop Pay, buy-now-pay-later Cards, plus country favourites: iDEAL (NL), Klarna and pay-by-invoice (DE, Nordics), Cartes Bancaires (FR), Bancontact (BE), Bizum (ES)
Where small-brand sneakers for this market are made China, Vietnam, Mexico, Portugal (with duty) Portugal, Spain, Italy (no duty); Turkey, China (with duty)
Import duty on a pair made elsewhere The Chapter 64 rate, from under 10% for leather uppers to 20% and well beyond for textile and synthetic, plus additional country-of-origin tariffs layered on since 2025 ~8% for leather uppers, ~17% for textile or synthetic uppers, plus import VAT; 0% if made in the EU
Sizing shown US, with half sizes EU, often whole sizes only; UK sizes in the UK
Trademark office USPTO, ~$350 per class, 8–14 months EUIPO, ~€850 for one class covering all 27 countries, 5–8 months; UKIPO separately
Design protection Design patent: slow and expensive Registered Community Design, ~€350 and weeks; unregistered design for three years from first disclosure
Core compliance Country-of-origin marking, Proposition 65, state chemical laws, CPSIA if for children Origin marking, material pictograms, REACH, GPSR, producer-responsibility and packaging schemes, a product passport on the way
Marketing law CAN-SPAM (opt-out), FTC endorsement rules GDPR (opt-in), cookie consent, a 30-day prior-price rule on discounts, influencer disclosure
Main trade shows Magic and Project (Las Vegas), the Atlanta Shoe Market, FFANY (New York) Micam (Milan), Pitti Uomo (Florence), Expo Riva Schuh (Garda), Paris showrooms during fashion week, CIFF (Copenhagen)

All figures are indicative. Rates, thresholds and laws change; the rest of the page explains each row and tells you what to verify.

Making

Proximity decides more than price

For a European brand, Portugal, Spain and Italy are days away by road, inside the customs union, and speak enough English to develop a shoe over email and one visit. Module 11 already recommends Portugal for an EU-facing brand. The business reason is in the table above: no duty, no import VAT on entry, no sea freight, no customs broker. A €40 FOB pair in Felgueiras is a €42 pair at your door in Lyon or Berlin.

For a US brand the same Portuguese pair crosses the Atlantic: freight, a broker, the Chapter 64 duty, and whatever additional tariff applies to goods of EU origin that month. It is still often the right choice for a leather fashion sneaker, because the alternative, China, carries heavier country-specific tariffs on top of a Chapter 64 rate that is already higher for textile and synthetic uppers. Mexico (León) has become the near-shore answer for leather footwear into the US, with its own trade-agreement rules of origin to satisfy. Vietnam suits athletic volume and mostly won’t talk to you.

Duty is a design decision. Both the US and EU tariff schedules tax footwear by the material of the upper and of the sole. In both, a leather upper generally carries a lower rate than a textile or synthetic one, and the gap can exceed ten points. Choosing leather over knit for a US-bound shoe can change the landed cost by more than the leather costs. Get the classification from your broker before you finalise materials (Module 16), not after.

The border, in one paragraph each

Into the US. Every commercial import is classified under HTS Chapter 64 and taxed at that line’s rate plus any additional tariffs by country of origin, plus the Merchandise Processing Fee and, by sea, the Harbor Maintenance Fee. You need an EIN, a customs bond (single-entry is fine for one shipment) and a licensed broker. The de minimis exemption that once let small parcels in duty-free has been largely eliminated, so do not plan to ship pairs individually from abroad to avoid duty. A binding ruling from CBP is free and removes the guesswork; request it in Week 17.

Into the EU. One classification (CN, Chapter 64), one duty rate for the whole union, charged on the customs value plus freight and insurance. Then import VAT at the rate of the country of entry, which a VAT-registered business reclaims but must fund first. You need an EORI number. Goods made inside the EU and sold inside it cross no border at all. Goods going on to the UK, Switzerland or Norway clear customs a second time.

Into the UK. Separate since 2021. The UK Global Tariff taxes footwear on a similar structure, UK import VAT is 20%, and you need a UK EORI. One wrinkle matters to small brands: for consignments under £135 sold to UK consumers, the seller must charge UK VAT at the point of sale and be registered for it. Many EU brands simply don’t ship to the UK until the volume justifies the paperwork.

Making in the market you sell in

Primary market Make here Why
EU Portugal first; Spain or Italy for fashion-forward or luxury positioning Zero duty, short lead times, small MOQs, English-speaking factories
US Portugal or Mexico for leather; China through an agent for the lowest FOB and the best sole catalogues Portugal for the product story and quality, Mexico for proximity and trade terms, China for cost if you’ve modelled the tariffs honestly
Both, eventually Make in Portugal, ship to both One factory, one tech pack, one QC relationship. Accept the US duty as the price of simplicity

“Made in USA” is not realistic for a sneaker at small scale. The domestic supply chain for soles and components barely exists outside a few large plants, and the FTC’s standard for the claim is “all or virtually all” domestic content. “Made in Portugal” and “Made in Italy” sell in both markets.

Selling

The price on the page

In the US the price is shown before sales tax, which is added at checkout according to the customer’s state. In the EU the displayed price must include VAT. So a $140 shoe in the US and a €150 shoe in France are not the same price to you.

US at $140 France at €150 (20% VAT)
The customer pays $140 plus state sales tax at checkout €150, all in
Tax you remit Nothing out of the $140; sales tax is collected on top €25
You keep, before costs $140 €125, roughly $135

Price the EU store so that the net of VAT matches your US net, not the sticker. Then round to a whole number that looks right in euros; Module 18’s whole-number rule applies in both currencies.

Who collects the tax

US sales tax. Collected per state once you have nexus there: a physical presence, or economic nexus at a threshold commonly around $100,000 of sales into that state. At 250 pairs you’ll have nexus in your home state and nowhere else. Shopify’s tax tooling handles collection and reporting; register where it tells you to.

EU VAT. Register in your home country. For sales to consumers in other EU countries, below €10,000 a year in total you charge your home rate; above it you charge the customer’s country’s rate and file one quarterly return through the One-Stop Shop (OSS). A non-EU brand selling into the EU either registers for the Import One-Stop Shop (IOSS), which covers consignments up to €150 in value and lets you collect VAT at checkout, or lets the carrier collect VAT from the customer on delivery, which customers hate and which drives refused parcels. Decide this before your first EU sale.

What the customer can send back

EU: by law, an online customer can return any order within 14 days of delivery for any reason and receive a full refund including the original standard shipping. You may make the customer pay return postage only if you said so before purchase. Separately, a two-year legal guarantee covers defects. The generous policy in Module 22 already exceeds this; the point is that the law is a floor, not a courtesy.

US: no federal right of return. You set the policy and must display it; some states require it to be posted or else a default applies. The competitive floor is still free returns and free exchanges within 30 days.

Behaviour differs more than the law. German customers in particular order two sizes and return one; it is normal and expected, and brands that sell there price for it. Model 30% or more for Germany-heavy sales, and make the exchange the easy path everywhere.

Sizes

Americans shop in US sizes and expect half sizes: a men’s run of 7–13 with halves is 13 SKUs per colourway. Europeans shop in EU sizes, and many European brands run whole sizes only: 39–46 is 8 SKUs. The UK uses UK sizes. Show all three plus foot length in millimetres everywhere (Module 22), but build the run for the primary market. For a first drop sold mainly in Europe, a whole-size run is a legitimate way to cut SKUs by a third. For the US, skipping half sizes costs sales and raises returns.

Payment

A Shopify store with Shopify Payments or Stripe covers cards, Apple Pay and PayPal in both markets. In Europe, add the local methods or lose conversion: iDEAL in the Netherlands, Klarna and pay-by-invoice in Germany and the Nordics, Bancontact in Belgium, Cartes Bancaires in France. Most are a checkbox in the payment settings. In the US, Shop Pay and a buy-now-pay-later option matter more than any single local method.

Shipping and fulfilment

US: one country, one set of carriers (USPS, UPS, FedEx), one zone table. Self-fulfilment from home works for a first run anywhere in the country.

EU: one customs territory but 27 postal systems. Domestic parcels run roughly €5–8, cross-border within the EU €8–15, and the carriers are national (DHL, DPD, GLS, PostNL, Colissimo, Correos) with pan-European networks. Self-fulfil from your home country, offer the rest of the EU at a flat rate, and leave the UK, Switzerland and Norway off the list until volume justifies their customs paperwork. If you ever use a 3PL, the Netherlands and Germany are the usual hubs.

Stockists and marketplaces

Both markets have the independent-store tier that matters to you. In the US the credible fashion-sneaker stockists cluster in New York, Los Angeles, Chicago, San Francisco and a dozen second cities; in Europe in London, Paris, Berlin, Amsterdam, Copenhagen, Stockholm, Milan and Barcelona. Terms are similar: about 50% of retail, net 30–60, pro-forma for a first order, insurance and barcodes required. Europe adds a layer the US mostly lacks: country agents who represent a brand to the stores in their territory for 10–15% commission and expect exclusivity. Useful at step five of the growth pattern on the industry page, premature before it. The large marketplaces (SSENSE, END., Farfetch, Zalando) are not for a first run in either market.

Pre-orders and delivery promises

Pre-order funding (Module 19) works in both markets. The EU adds a rule: unless you agreed a date with the customer, goods must be delivered within 30 days, and a missed agreed date lets the customer cancel for a full refund. State the delivery window explicitly on the product page and in the confirmation email, and your pre-order is on the right side of the law in both places.

Marketing

Language and fragmentation

The US is one market with one language and national media, which is why paid social works there at scale and why it is expensive. Europe is ten markets pretending to be one. English carries you in the Netherlands, the Nordics and among the sneaker-literate audience everywhere, but a German or French customer buying a €150 shoe expects the product page, the size guide, the returns policy and the support reply in their language. Launch in English plus your home language; add German and French when those countries reach 20% of sales.

Press and stores carry more weight in Europe. A pair on the shelf of a respected independent in Paris or Berlin does what a paid campaign does in the US, for the cost of the wholesale margin on 24 pairs.

The rules on reaching people

US EU
Email CAN-SPAM: you may email until they opt out; include an unsubscribe link and a postal address GDPR and ePrivacy: explicit opt-in before marketing email, no pre-ticked boxes, and keep the record of consent
Cookies and tracking Light; state privacy laws, California first A consent banner before any non-essential cookie; Meta and Google pixels need consent
Influencer and seeded content FTC: disclose any material connection, including free product The same principle, enforced nationally; the Digital Services Act adds platform-level rules
Discounts Largely free; “was” prices must be genuine The 30-day rule: any announced reduction must show the lowest price of the previous 30 days; France, Italy and Belgium among others restrict seasonal sales to fixed dates
Sustainability claims FTC Green Guides: substantiate or don’t say it Rules banning generic claims such as “eco-friendly” without proof, and restricting offset-based claims, apply from 2026. Be specific or be silent

For a brand with a list of 500 people, GDPR costs nothing but care: a clear sign-up, a stored consent, a working unsubscribe. The discount rule is a bigger deal than it looks, because it removes the “launch high, discount fast” play, which Module 18 already told you not to run.

Where the culture lives

Both markets share the global sneaker media (Hypebeast, Highsnobiety, Sneaker Freaker) and the same platforms. The difference is in the second tier. In the US: Complex, Sneaker News, Footwear News for the trade, and the stores whose accounts are media in their own right. In Europe: national sneaker press in German, French and Dutch, the store network (Sneakersnstuff, END., Footpatrol, Overkill, Solebox, 43einhalb, Patta, Slam Jam, Titolo, Starcow) and fashion-week showrooms. For your positioning the European comparison set is stronger: Veja, Axel Arigato, Common Projects, Zespa, CQP, Flamingos’ Life. US readers know them too. Lean into that.

Compliance

The rules you must meet before the first pair ships, by market. Module 16 covers labelling and customs in practice; this is the wider list, so nothing surprises you later. Verify each against the current text when you are within eight weeks of shipping.

Area US EU
Origin and labelling Permanent, conspicuous country-of-origin marking on the shoe, and on the box for retail Origin marking plus the material pictograms for upper, lining and sock, and outsole, on the shoe and at point of sale
Chemicals California Proposition 65 warnings for listed substances; state PFAS bans on apparel and textiles phasing in from 2025 and widening; CPSIA lead limits, testing and a tracking label if the shoe is for children REACH: restricted substances (chrome VI in leather, azo dyes, phthalates, nickel) and disclosure of substances of very high concern; PFAS restrictions in progress. A restricted-substances list and a factory test report are your evidence
Product safety A general duty of care; CPSC oversight for children’s products GPSR, in force since December 2024: a named responsible economic operator established in the EU, traceability information on the product or packaging, a risk assessment on file, an EU contact for recalls. A non-EU brand must appoint one
Liability Tort exposure is higher; stockists demand product liability insurance A new Product Liability Directive adopted in 2024 keeps strict liability for defective products; stockists expect insurance here too
Waste and packaging Few obligations at this scale; state packaging laws emerging Producer responsibility: France already requires registration and fees for textiles and footwear (the Refashion scheme) and for packaging (the Triman logo); Germany requires packaging registration (LUCID); EU-wide textile and footwear schemes are being rolled out under the revised Waste Framework Directive
Traceability Nothing yet A Digital Product Passport for footwear under the Ecodesign regulation, expected later this decade. Keep your BOM and supplier data clean now and it will cost nothing then
Leather sourcing Nothing The deforestation regulation (EUDR) covers bovine leather; application dates have moved and small businesses get later deadlines. Ask your tannery for its due-diligence position

The EU column is longer. At your scale it is mostly paperwork rather than cost: a registered responsible person, a few registrations with fees in the tens to low hundreds of euros a year, and a test report you wanted anyway. The US column is shorter but its liability line is where the money is. Insure accordingly.

Entity, IP and money

Where to be a company

US EU
Default form An LLC in your home state; Delaware or Wyoming only if you have a reason France: SAS, or micro-entreprise to test; Germany: GmbH or UG; Netherlands: BV; Portugal: Lda; UK: Ltd
Cost to form $50–500 plus a registered agent €0–1,000 depending on country; a GmbH needs €25,000 of share capital, a UG needs €1
Selling into the other market without an entity there A non-EU company can sell DTC into the EU with a VAT or IOSS registration, an EU-established responsible person under GPSR, and an importer of record: often the customer under delivered-duty-paid terms, or a fiscal representative A non-US company can sell DTC into the US with an EIN, a customs bond and a broker acting for it as importer, sales-tax registration once nexus triggers, and US product liability cover

Module 17’s rule stands: form the entity before the bulk order, in the country you live in. Do not form a second entity abroad for drop one.

Trademarks and designs

File first in the market you sell in first. A USPTO filing covers the US only. An EU trademark covers all 27 members in one filing at one fee, which is why it’s good value even at ~€850; the UK needs its own filing. In both, search before you commit to the name (Module 17).

Designs diverge. In the EU a Registered Community Design costs about €350, registers in weeks and can last 25 years; an unregistered Community design protects a new design automatically for three years from its first public disclosure in the EU, so record the date you first show the shoe. The US equivalent is a design patent: $1,000–3,000 with an attorney and a year or more to grant. For a first silhouette on an open mold, the EU registered design is worth having; the US design patent usually is not.

Money and currency

Sell in the customer’s currency. Hold a multi-currency business account (Wise, Revolut Business, or a bank that offers one) so that euro revenue pays a Portuguese factory without two conversions. Card processing costs are similar on both sides; European interchange fees are capped lower, so it’s slightly cheaper there. Chargebacks are more common in the US. Refused VAT-on-delivery parcels are the European equivalent, which is one more reason to use IOSS or price delivered-duty-paid.

Small-business support differs. European founders have national schemes worth an afternoon’s research (Bpifrance in France, IAPMEI in Portugal, KfW in Germany, plus regional grants); US founders have SBA microloans and state programmes. None of them replace pre-orders as the funding mechanism (Module 19). Some will pay for a trade-show stand or a trademark.

Choosing the primary market

The rule: sell first where you live, make where it zeroes the duty for that market if you can, and schedule the second market as a dated phase with its own checklist.

Signal Points to
You live there Your primary market, almost always. You can self-fulfil, run pop-ups, visit stockists, and comply in a system you understand
Your factory is there A strong second signal. A Portuguese factory and an EU customer base is the simplest business on this page
Your list is there Where the 500 people on your email list live is where drop one sells
Your comparison brands are strongest there For a minimal leather sneaker, Europe
Half sizes are a problem A whole-size EU run is cheaper to stock
Paid social is your plan The US, but reread Module 23 on why it shouldn’t be the plan

Entry checklist: adding the EU

Entry checklist: adding the US

Do this

  1. Pick the primary market (30 minutes). Use the signals table. Write the decision and the date into your one-page plan.
  2. Reprice for it (1 hour). Build the VAT-inclusive or ex-tax price so that your net per pair is the same in both markets. Put both in the unit-economics tab.
  3. Run your shoe through the duty logic (1 hour). Material of upper, material of sole, country of origin, destination. Write down the rate your broker should confirm, and the rate it would be with the other upper material.
  4. Fill the entry checklist for the primary market (2 hours). Date each line. Anything you can’t date is a row in the risk table.
  5. Schedule the second market (30 minutes). A quarter, not a wish. Its checklist is the first task of that quarter.

Self-check

  • What is your net per pair in each market after VAT or sales tax, and are the two within 5% of each other?
  • Which compliance item on your primary-market checklist has the longest lead time, and have you started it?
  • If a German customer orders two sizes and returns one, what does that order earn you?
  • Who is your EU responsible person, or your US importer of record, by name?

Traps

  • Treating Europe as one market. It’s one border and one VAT return, and then it’s ten countries with their own language, carriers, payment methods and sale dates.
  • Shipping to the UK because it’s close. It’s a third country with its own VAT-at-checkout rule for small parcels. Add it on purpose or not at all.
  • Copying a US price into euros. €140 includes VAT. You just gave away 17–21% of the price.
  • Launching on last year’s tariff number. US country-of-origin tariffs have changed repeatedly since 2025. The broker’s number from this month is the only one that counts.
  • Discounting in the EU the American way. The 30-day rule and the fixed sale dates apply, and the fines are real.
  • A second market before the first is profitable. Every row above doubles. Do it at step five of the growth pattern, not step one.