Not all countries treat prize promotions the same. A mechanic that works fine in the UK might get you fined in Italy, rejected in Canada, or just quietly ignored in France.
This page highlights key differences across major markets — the sort of things worth catching before you print 500,000 packs.
I don’t offer legal advice. I review your promotion, flag issues, and point out where local input is essential. It’s about clarity, risk awareness, and not looking clueless on shelf.
Italy
- A notary must oversee prize draws.
- You’ll need a legal deposit lodged with the Ministry.
- Instant win promotions are tightly regulated and usually require pre-approval.
Translation: you can’t just run a UK-style promo and hope for the best.
Canada
- Skill-testing question required, and it has to be more than 1+1.
- Quebec has additional language, tax, and registration requirements.
- Prizes may be taxed as income.
Run a “no purchase necessary” promo in Canada without reading the rules and you’ll likely break them.
United States
- Sweepstakes may need to be registered in NY, FL, and RI if prize value exceeds local thresholds.
- Winners must receive a 1099 tax form.
- “No purchase necessary” is a hard legal requirement, not a vague disclaimer.
Also: Americans sue. So your T&Cs better hold up.
Ireland
- Promotions that look like lotteries may fall under strict gambling rules.
- “No purchase necessary” isn’t enough. Clarity around entry method is key.
- Prize games often require written consent from authorities.
You can’t call it a lottery and claim it’s not.
France
- Local data protection law (CNIL) is stricter than GDPR in some cases.
- Wording around opt-ins and consent needs to be watertight.
- Cash alternatives may be expected, or at least offered.
French consumers aren’t thrilled by vague or overhyped claims. Expect scrutiny.
My Role
I won’t replace a legal team. But I’ll help you avoid obvious errors, assumptions, and costly reprints.
If you’re adapting a UK promotion for Europe or beyond, I’ll review the mechanic, flag regional red flags, and suggest how to adjust without losing clarity or breaking local rules.
Want help?
Drop me a note and I’ll tell you what’s safe, what’s shaky, and where to tread carefully.
I take confidentiality seriously. Anything you share with me, whether it’s campaign details, draft artwork, or strategic thinking, stays strictly between us. I don’t publish, reuse or reference client work without explicit permission.
If needed, I’m happy to sign an NDA before reviewing any materials.