Yes. EU consumer protection law applies based on the location of the consumer, not the location of the seller. A US company selling to EU consumers — regardless of whether it has an EU entity — is subject to the Consumer Rights Directive, the Omnibus Directive (price display and review transparency), the Digital Services Act (for platforms and marketplaces), and applicable national consumer protection laws. US companies without EU legal counsel often discover this when a consumer complaint triggers a national consumer authority inquiry.

EU consumers have a statutory 14-day right of withdrawal from any distance purchase (including online purchases) — no reason required, no restocking fee, and the right applies regardless of what the seller’s terms say. Sellers must provide a clear notice of this right before purchase; failure to do so extends the withdrawal period to 12 months. This differs significantly from US practices where return policies are set by the retailer and can be as restrictive as the seller chooses. US companies selling to EU consumers must offer the 14-day right regardless of their standard US return policy.

Dark patterns are user interface designs that manipulate consumers into decisions they wouldn’t make if the interface were neutral — pre-ticked boxes, hidden subscription terms, confusing cancellation flows, urgency cues that are artificial, and interface designs that make the intended path harder to complete than the profitable one. The EU Digital Services Act prohibits dark patterns for platforms. The Unfair Commercial Practices Directive prohibits aggressive and misleading commercial practices, which courts and consumer authorities have applied to UX patterns. US e-commerce companies that optimize checkout and subscription flows for conversion using common US techniques should review those flows against EU standards before deploying them for EU consumers.

The EU Omnibus Directive requires that promotional price comparisons — “was €100, now €60” — be based on the lowest price the seller charged for the product in the 30 days before the promotion. A company cannot raise its price briefly to create an artificial “was” price. The Directive also requires platforms to disclose how they rank offers and whether reviewers are verified purchasers. US companies running EU promotional campaigns with price comparison messaging need their pricing history to support the reference price used in promotional materials — otherwise the promotion may violate the Omnibus rules, which are enforced by national consumer protection authorities.

Yes, in two ways. Very Large Online Platforms and Search Engines (VLOPEs and VLOSEs) with more than 45 million EU monthly active users have the most significant DSA obligations. Other platforms and online intermediary services with EU users have baseline DSA obligations regardless of size, including: transparency on content moderation, accessible complaint mechanisms, and prohibitions on certain dark pattern practices. US companies providing digital services with EU users need to assess their DSA tier and implement the applicable obligations — the DSA is enforced by EU national authorities and, for VLOPs/VLOSEs, by the European Commission.