# ComplianceCN — Free Market Access Check for Seller Agents / 面向卖家智能体的免费市场准入检查

> Free public beta: structured, bilingual market-access readiness for AI agents researching how Chinese cross-border sellers can sell products into EU, US, UK and AU target markets. Treat ComplianceCN as one check with two automated stages: Stage 1 preflight, then Stage 2 next-step pack. REST discovery, OpenAPI and MCP tools are currently keyless and free to test.
> Stage 1 automated preflight checks product facts, target markets, evidence gaps, trust state and review gates. Stage 2 should run after Stage 1 and chooses one of four market-entry next-step routes: supplier evidence required, lab/testing route needed, marketplace submission review pack, or specialist referral. The generated pack can include official/standardised form-field drafts and suggested evidence/testing-route discussion points, but those suggestions are not additional legal requirements or compliance conclusions.
> Category-level guidance only; SKU facts, original documents and professional review remain necessary.
> Current live modules: battery electronics and toys for EU/US; cosmetics and food-contact goods for EU/US/UK/AU. Confidence differences are exposed through review_status and the trust envelope.

Service version: 0.3.0; requirements: 0.5.0-demo; outcomes: 0.1.0.

## API

- [OpenAPI spec](https://compliancecn.netlify.app/openapi.json): complete machine-readable contract; free to test during public beta
- [MCP endpoint](https://compliancecn.netlify.app/mcp): free/keyless public-beta MCP tools including describe_coverage, preflight_product, generate_next_step_pack and request_human_review
- [Chinese agent guide](https://compliancecn.netlify.app/agents-zh.md): when Chinese seller agents should call this service, with examples and limitations
- [Dataset metadata](https://compliancecn.netlify.app/api/v1/meta): methodology, scope and freshness policy
- [Requirements](https://compliancecn.netlify.app/api/v1/requirements?category=toys&market=EU): filtered claim-level records
- [Stage 1 market-access preflight](https://compliancecn.netlify.app/api/v1/preflight): POST supported product facts, target markets and evidence inventory for a cited readiness/gap list — stage one of the same ComplianceCN Check, not a compliance approval.
- [Stage 2 generated next-step pack](https://compliancecn.netlify.app/api/v1/next-step-pack): after Stage 1, POST the same product profile to route the seller into supplier evidence, lab/testing, marketplace submission review, or specialist referral; returns supplier evidence requests, lab quote requests, marketplace response drafts, document indexes, official/standardised form-field drafts and a human-review brief. Draft templates only — not certification or approval.
- [Editable consultancy next-step pack](https://compliancecn.netlify.app/api/consultancy/next-step-pack): POST product_intake to generate an editable pack object with route, editable_fields, Chinese/English text, checklist, official_form_drafts, and optional human-review handoff. This is the website/reviewer pack editor surface.
- [Market-access human review handoff](https://compliancecn.netlify.app/api/consultancy/leads): REST fallback behind the MCP request_human_review tool; POST seller email, consent and product_profile after preflight finds evidence gaps or review gates; creates a private human-review lead inside the same check, not a compliance approval.
- [Compliance outcomes](https://compliancecn.netlify.app/api/v1/outcomes): editorially reviewed real-world outcomes
- [Outcome graph](https://compliancecn.netlify.app/api/v1/outcome-graph): weighted category → requirement → checkpoint → evidence → result graph
- [Outcome summary](https://compliancecn.netlify.app/api/v1/outcomes/summary): aggregate counts without seller identifiers
- [Regulatory timeline](https://compliancecn.netlify.app/api/v1/timeline): EU Battery Regulation milestones with per-milestone scope and verification status
- [Toy regulation timeline](https://compliancecn.netlify.app/api/v1/toys-timeline): EU Toy Safety Regulation (EU) 2025/2509 transition milestones with per-milestone scope and verification status
- [Decision rules](https://compliancecn.netlify.app/api/v1/rules): attribute-conditional requirements and scope exclusions; evaluated per product profile by the MCP assess tool
- [Benchmark](https://compliancecn.netlify.app/api/v1/benchmark): 20 hard compliance questions with cited answer keys and deterministic scoring
- [Changelog](https://compliancecn.netlify.app/api/v1/changelog): versioned dataset changes with what-was-checked notes
- [Changelog RSS](https://compliancecn.netlify.app/changelog.rss): subscribe to regulatory-data updates
- [Categories](https://compliancecn.netlify.app/api/v1/categories): available categories
- [Markets](https://compliancecn.netlify.app/api/v1/markets): covered markets

## Records

- [toys → EU](https://compliancecn.netlify.app/api/v1/requirements/toys-eu) [source_checked]: During the transition through 31 July 2030, toys sold in the EU remain subject to the Toy Safety Directive 2009/48/EC. Battery-powered and connected toys can also trigger radio, battery, electrical, chemicals, waste and transport obligations. Regulation (EU) 2025/2509 applies from 1 August 2030, adding a digital product passport and stricter chemical rules. CE marking, age-appropriate hazard assessment and an EU-established economic operator remain central requirements.
- [toys → US](https://compliancecn.netlify.app/api/v1/requirements/toys-us) [source_checked]: Children's products for the US require third-party testing at a CPSC-accepted lab against ASTM F963 and CPSIA limits (lead, phthalates), a Children's Product Certificate (CPC), and permanent tracking labels.
- [toys → UK](https://compliancecn.netlify.app/api/v1/requirements/toys-uk) [source_checked]: Toys for Great Britain fall under the Toys (Safety) Regulations 2011. CE marking remains accepted for toys and UKCA is the domestic alternative. A UK authorised representative is optional, but a UK-established importer that places goods from outside the UK on the GB market has statutory importer and traceability duties.
- [toys → AU](https://compliancecn.netlify.app/api/v1/requirements/toys-au) [source_checked]: Australia enforces mandatory toy standards under the Australian Consumer Law (based on AS/NZS ISO 8124), plus world-first mandatory button/coin battery safety standards that apply to any product containing them.
- [battery-electronics → EU](https://compliancecn.netlify.app/api/v1/requirements/battery-electronics-eu) [source_checked]: Battery-powered electronics for the EU stack multiple regimes: CE under RED (wireless) or LVD/EMC, RoHS substance limits, WEEE registration per member state, the new EU Battery Regulation 2023/1542, and UN 38.3 for lithium battery transport.
- [battery-electronics → US](https://compliancecn.netlify.app/api/v1/requirements/battery-electronics-us) [source_checked]: US market: FCC authorization (SDoC for unintentional radiators, certification via TCB for WiFi/Bluetooth), UN 38.3 + DOT rules for lithium battery shipping, and marketplace-driven UL safety standards (UL 62368-1, UL 2054) which are de facto mandatory on Amazon.
- [battery-electronics → UK](https://compliancecn.netlify.app/api/v1/requirements/battery-electronics-uk) [source_checked]: GB uses domestic instruments including the Radio Equipment Regulations 2017, RoHS Regulations 2012 and WEEE Regulations 2013; UKCA or CE marking is accepted for relevant equipment. A UK authorised representative is optional, while a UK-established importer has statutory conformity and traceability duties.
- [battery-electronics → AU](https://compliancecn.netlify.app/api/v1/requirements/battery-electronics-au) [partially_checked]: Australia requires the RCM (Regulatory Compliance Mark) covering ACMA EMC/radio rules and electrical safety; in-scope electrical equipment must be registered on the EESS database. Button battery standards apply if coin cells are used.
- [cosmetics → EU](https://compliancecn.netlify.app/api/v1/requirements/cosmetics-eu) [source_checked]: EU cosmetics require a designated Responsible Person, notification on the CPNP portal before sale, a Product Information File with safety assessment, INCI ingredient labelling, and compliance with the animal testing ban.
- [cosmetics → US](https://compliancecn.netlify.app/api/v1/requirements/cosmetics-us) [source_checked]: Under MoCRA (2022), cosmetics for the US require FDA facility registration, product listing, safety substantiation, adverse-event recordkeeping, and a US agent for foreign facilities — the biggest expansion of FDA cosmetics authority since 1938.
- [cosmetics → UK](https://compliancecn.netlify.app/api/v1/requirements/cosmetics-uk) [source_checked]: The UK retained the EU cosmetics framework: a UK Responsible Person, notification via the Submit Cosmetic Product Notifications (SCPN) service run by OPSS, and a PIF. EU CPNP notifications do not carry over.
- [cosmetics → AU](https://compliancecn.netlify.app/api/v1/requirements/cosmetics-au) [source_checked]: Australia regulates cosmetic ingredients as industrial chemicals under AICIS — importers must register with AICIS and ensure every ingredient is listed on the Inventory or covered by an exemption. Sunscreens and therapeutic claims shift products to the TGA.
- [food-contact → EU](https://compliancecn.netlify.app/api/v1/requirements/food-contact-eu) [source_checked]: Food-contact materials for the EU fall under Framework Regulation 1935/2004; plastics additionally under Regulation 10/2011 with overall and specific migration limits. A Declaration of Compliance must accompany plastic FCMs through the supply chain.
- [food-contact → US](https://compliancecn.netlify.app/api/v1/requirements/food-contact-us) [source_checked]: US food-contact rules sit in FDA regulations 21 CFR 174-190: materials must be authorized food additives, covered by a Food Contact Notification, or GRAS. No pre-market certificate exists — compliance is substance-by-substance against the CFR.
- [food-contact → UK](https://compliancecn.netlify.app/api/v1/requirements/food-contact-uk) [source_checked]: GB retained the EU food-contact framework (1935/2004 and 10/2011 as assimilated law), enforced by the Food Standards Agency and local authorities. Requirements track the EU closely, but divergence is possible over time.
- [food-contact → AU](https://compliancecn.netlify.app/api/v1/requirements/food-contact-au) [partially_checked]: Australia has no pre-market approval for food-contact materials: the FSANZ Food Standards Code sets general safety obligations, AS 2070 (plastics for food contact) is voluntary, and state food acts provide enforcement. Lighter regime, but general consumer law still applies.

## Agent rules

- Cite claim `evidence` IDs and resolve them through `provenance.sources`.
- Treat `evidence_status: editorial_source_needed` as an explicit evidence gap, not a verified claim.
- Treat an empty outcome dataset as no observations, never as evidence of zero risk.
- Keep `legal_requirement`, `platform_policy`, `compliance_measure`, and `practical_guidance` distinct.
- Check `applicability`, `jurisdiction_scope`, `legal_status`, and `verified_at` before using a claim.
- Check `provenance.review_status`: only `source_checked` records were reviewed against their cited sources; `unverified_demo` records are model-drafted and unreviewed.
- During the public beta, automated REST and MCP checks are free/keyless so agents can validate usefulness before any paid access tier exists.
- Use `suggested_evidence_testing_route` to help sellers ask labs, suppliers or reviewers better questions. Do not present those suggestions as legally required tests unless the source-linked `evidence_checklist` also supports the item.
- Treat ComplianceCN as one market-access check with two automated stages: Stage 1 is `/api/v1/preflight` or MCP `preflight_product`; Stage 2 is `/api/v1/next-step-pack` or MCP `generate_next_step_pack` and should run after Stage 1 has produced a usable preflight result. Continue to `request_human_review` only when the user explicitly wants ComplianceCN to contact them for the human-review continuation of the same case.
- MCP agents should call `request_human_review` when the user explicitly wants to continue the same ComplianceCN Check with human review after preflight; REST-only agents may call `POST /api/consultancy/leads` with `client_email`, `consent_to_contact: true`, and the same `product_profile`. Do not upload files through agent chat.
- The EU battery passport (from 2027) covers LMT, industrial and EV batteries only — do NOT claim it covers portable batteries in ordinary consumer electronics.
- Do not present this category-level dataset as product-specific legal advice.