Restricted Products
Restricted Products
& Platform Integrity Policy
The global B2B marketplace connecting buyers, suppliers & manufacturers across 180+ countries. This policy sets binding standards for all users, listings, and transactions ensuring legal compliance · protecting intellectual property · safeguarding every participant.
Scope & Purpose
This Restricted Products & Platform Integrity Policy ("Policy") applies to every account, listing, transaction, message, and data record on XB2BX.COM ("Platform"), operated by XB2BX Global Commerce Ltd. ("Company", "we", "us"). It binds all registered sellers, buyers, agents, and any third party accessing the Platform regardless of jurisdiction.
The Policy exists to: (i) ensure compliance with applicable international trade law, export controls, and sanctions regimes; (ii) protect users' intellectual property and personal data; (iii) maintain marketplace integrity and trust; and (iv) limit the Company's legal exposure and that of its users.
Governing Frameworks
The Platform operates under, and this Policy is designed to comply with: EU Regulation (EU) 2022/2560 (Foreign Subsidies), US Export Administration Regulations (EAR), OFAC Consolidated Sanctions List, WTO Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS), GDPR (EU) 2016/679, UK GDPR, California Consumer Privacy Act (CCPA/CPRA), and all local consumer protection statutes in jurisdictions where the Platform operates.
Absolutely Prohibited Products & Conduct
- Firearms, ammunition, suppressors
- Military-grade explosives
- Chemical, biological, nuclear, or radiological weapons or precursors
- Anti-personnel landmines & cluster munitions
- Narcotics & Schedule I/II substances
- Precursor chemicals (INCB List I & II)
- Unregistered pharmaceuticals & counterfeit medicines
- Novel psychoactive substances (NPS)
- Any form of human trafficking
- Forced labour facilitation
- Child labour products (ILO Convention 182)
- Illegal organ or tissue trade
- CITES Appendix I species & derivatives
- Ivory, rhino horn, shark fins
- Illegal timber (EUTR / US Lacey Act)
- Protected coral & marine species
- Goods bearing unauthorised trademarks
- Pirated software, media, & designs
- Fake certificates of origin
- Currency counterfeiting equipment
- Stolen goods of any kind
- Hacking tools & malware
- Stolen personal data or credentials
- Identity documents, seals, stamps
Controlled Product Categories
The following categories may be listed only by sellers who have completed XB2BX Enhanced Verification ("EV") and submitted the required documentation. Listings in these categories are subject to enhanced monitoring and periodic re-verification.
- Pesticides requiring import licences
- Restricted-use herbicides
- Fertiliser compounds (>16% ammonium nitrate)
- Class II/III medical devices
- Prescription-only medicines (bulk)
- Diagnostic equipment requiring CE/FDA clearance
- EAR-controlled semiconductors & chips
- Encryption software (>64-bit)
- Night-vision / thermal imaging equipment
- Drones (>25 kg MTOW)
- UN dangerous goods (Classes 1–9)
- Radioactive materials (non-weapons)
- Industrial solvents & acids
- BSL-2+ biological materials
- Select agents (CDC/USDA listed)
- High-powered lasers (>Class 3R)
- Spirits & wines (bulk wholesale)
- Tobacco & e-cigarette products
- CBD / hemp derivatives by jurisdiction
Enhanced Verification Requirements
Sellers in controlled categories must submit: (a) valid business registration in country of origin; (b) relevant export licences or permits; (c) proof of manufacturing authorisation or distributor agreement; (d) evidence of compliance with destination-country import regulations. XB2BX reserves the right to request updated documentation annually or upon regulatory change.
Restricted Products — Approval Required
A broader range of products requires prior category approval before listing. These are lawful in most jurisdictions but carry elevated compliance obligations. The approval process typically takes 5–10 business days.
- Sporting rifles & shotguns (licensed)
- Airsoft & paintball equipment
- Shooting range equipment
- Novel foods (EU 2015/2283)
- Sports & protein supplements (bulk)
- Traditional herbal medicines
- Gold / silver bullion >$10,000/tx
- Conflict mineral compliance required
- KYC/AML documentation mandatory
- Mining explosives (commercial)
- Detonators & initiating systems
- Tunnelling machinery
Seller Obligations
Listing Accuracy
Sellers must provide complete, accurate, and non-misleading product descriptions, including correct HS tariff codes, country of origin, material safety data sheets (where applicable), and all certifications required by the destination market. Misrepresentation of product classification to circumvent this Policy is a material breach.
Sanctions Screening
Sellers are required to screen all buyers, shipping addresses, and end users against OFAC SDN, EU Consolidated Sanctions, UN Security Council Sanctions, and any applicable national lists before accepting any order. The Platform provides a built-in sanctions screening tool, but use of that tool does not transfer compliance responsibility from the seller to XB2BX.
Export Controls
Where goods are subject to export licensing, sellers must obtain all required licences prior to transaction completion. Sellers must retain export documentation for a minimum of seven (7) years and provide copies to XB2BX upon request within five (5) business days.
Seller Compliance Certification
By activating a seller account, you certify under penalty of account termination and civil liability that all listings comply with this Policy, that you hold all required licences, and that you will not knowingly transact with sanctioned entities, embargoed territories, or parties engaged in prohibited end-uses.
Buyer Obligations
Buyers on XB2BX.COM are responsible for ensuring that: (i) imported goods comply with all destination-country regulations; (ii) applicable import permits are obtained before confirming orders; (iii) goods are not re-exported to prohibited destinations or end-users; and (iv) correct import duties and taxes are declared and paid.
End-Use Declarations
For dual-use goods, controlled technologies, and any product flagged by the Platform's compliance engine, buyers must complete a binding End-Use Declaration stating the exact intended use and certifying that goods will not be diverted to weapons programmes or prohibited parties. False declarations may result in criminal liability under applicable trade law.
KYC Requirements
Buyers transacting above USD $10,000 per calendar quarter, or in any controlled category, must complete Know Your Customer (KYC) verification including: government-issued business registration, proof of premises, UBO (Ultimate Beneficial Ownership) disclosure, and source-of-funds declaration where required.
Enforcement & Penalties
XB2BX employs automated listing review, AI-assisted image and text scanning, manual compliance review, and third-party audit mechanisms to detect Policy violations. The enforcement framework is tiered by severity:
| Severity | Example Breach | Immediate Action | Ongoing Consequence |
|---|---|---|---|
| CRITICAL | Prohibited product listing, sanctions breach, human exploitation | Immediate account suspension, funds frozen, law enforcement referral | Permanent ban, potential civil / criminal referral |
| HIGH | Counterfeit goods, false product classification, unlicensed controlled sale | Listing removal, 30-day suspension, escrow hold | Repeated breach = permanent ban; IP holder notified |
| MEDIUM | Missing certifications, inaccurate HS codes, incomplete EUC | Listing paused; 14-day cure period issued | Failure to cure = listing removal; trust score reduced |
| LOW | Incomplete product descriptions, minor labelling errors | Correction notice issued; 7-day cure period | Persistent non-compliance reduces search ranking |
Appeals Process
Users who believe an enforcement action was taken in error may submit a formal appeal. Appeals must be lodged within 14 calendar days of the enforcement notice. Appeals received after this window will not be considered except in exceptional circumstances.
Submit Appeal
File via the Appeals Portal at compliance.xb2bx.com/appeals, providing account ID, enforcement notice reference, and a written statement with supporting documentation.
Acknowledgement (48 Hours)
XB2BX will acknowledge receipt within 48 business hours and assign a case reference number. The assigned compliance officer will review the appeal within 10 business days.
Review & Decision
The Compliance Review Panel will issue a written decision. For Critical or High severity cases, decisions are reviewed by a senior compliance officer before issue.
Final Escalation
If unsatisfied with the panel decision, users may escalate to the XB2BX Chief Compliance Officer within 7 days of panel decision. The CCO decision is final and binding.
External Dispute Resolution
Users retain the right to pursue applicable legal remedies or ADR mechanisms. Arbitration in disputes involving EU users is governed by ICC Rules, seated in London.
Intellectual Property & Brand Protection
XB2BX operates a zero-tolerance approach to intellectual property infringement and participates in the following brand protection programmes:
IP Rights Holder Programme
Verified IP rights holders may enrol in the XB2BX Brand Registry to receive proactive monitoring, automated listing takedowns, and priority escalation. Registration requires proof of trademark registration or pending application in at least one jurisdiction.
Notice & Takedown
Any party who believes their intellectual property rights are being infringed on the Platform may submit a takedown notice to ip@xb2bx.com including: identification of the IP right, evidence of ownership, identification of the infringing material, and a good-faith statement. XB2BX will act on valid notices within 24 hours on business days.
Counter-Notice
Sellers who believe a takedown was issued in error may submit a counter-notice within 10 business days. XB2BX will reinstate the listing within 14 business days of a valid counter-notice unless the IP rights holder initiates legal proceedings.
Data Privacy & Security
XB2BX processes personal data as both a Data Controller (for account and platform data) and a Data Processor (for transaction data processed on behalf of sellers). All processing is governed by the XB2BX Privacy Policy, incorporated herein by reference, and the following binding commitments.
Data Collected
| Category | Data Elements | Legal Basis | Retention |
|---|---|---|---|
| Account Data | Name, email, business details, UBO info | Contract performance | 5 years post-closure |
| Transaction Data | Order details, payment refs, shipping info | Legal obligation (tax/AML) | 7 years |
| Compliance Data | KYC documents, EUC declarations, sanctions checks | Legal obligation | 7 years |
| Behavioural Data | Click data, search history, session logs | Legitimate interest | Anonymised at 24 months |
| Marketing Data | Email preferences, campaign interactions | Consent | Deleted on withdrawal |
Data Security Standards
All personal data is encrypted at rest (AES-256) and in transit (TLS 1.3). XB2BX maintains ISO 27001 certification and conducts annual penetration testing by an accredited third party. Access to personal data is restricted by role-based access controls and multi-factor authentication. Data breaches affecting EU/UK residents will be notified to relevant supervisory authorities within 72 hours of discovery.
International Transfers
Where personal data is transferred outside the EEA or UK, XB2BX implements appropriate safeguards including Standard Contractual Clauses (SCCs), UK International Data Transfer Agreements (IDTAs), or adequacy decisions as applicable. A full list of sub-processors is available at privacy.xb2bx.com.
User Rights
Registered users and other data subjects have the following rights regarding their personal data processed by XB2BX, exercisable by submitting a verified request to privacy@xb2bx.com:
Obtain a copy of all personal data held about you, including the purposes for which it is processed and any third parties to whom it has been disclosed.
Correct inaccurate or incomplete personal data. Requests will be acted upon within 30 days (extendable to 90 days for complex requests).
Request deletion of personal data where no overriding legal obligation requires retention. Note that AML and tax data is subject to mandatory retention periods.
Receive your account and transaction data in a structured, machine-readable format (JSON/CSV) for transfer to another platform or service.
Object to processing based on legitimate interests or for direct marketing purposes at any time. Marketing objections are actioned immediately.
Request that processing be restricted while accuracy is contested or an objection is being considered. Restricted data is stored but not actively processed.
Users in California (CCPA/CPRA) additionally have the right to opt out of the sale or sharing of personal information and to limit the use of sensitive personal information. XB2BX does not sell personal data to third parties. All user rights requests will receive an initial response within 30 calendar days.
Contact, Reporting & Governance
Report a Violation
Suspected violations of this Policy — including prohibited listings, counterfeit goods, sanctions concerns, or data misuse — can be reported through the following channels. All reports are reviewed within 24 business hours. Whistleblowers are protected from retaliation under Platform rules and applicable law.
Policy Governance
This Policy is owned by the XB2BX Chief Compliance Officer and reviewed quarterly by the Platform Governance Committee. Material updates will be announced to all registered users via email with a minimum 30-day notice period before coming into force, except where immediate updates are required by law. The current version supersedes all prior versions. Archived versions are available upon request.
