Food safety requirements are considered to be one of the main barriers to farmers' involvement in short supply chains (SSCs), hence the study aims to identify which requirements apply under legislation of the UE, selected Member States (Poland, Italy, France) and the USA, and based on their comparison to draw conclusions whether they are appropriate for the SSCs. The EU did not foresee a specific set of hygiene rules for the SSC, but it did provide for some flexibility, not because of the geographical proximity of the producer and the consumer, but depending on the sales channel, i.e. without intermediaries (direct delivery), characteristics and volume of the food (i.e. processed or unprocessed, traditional, in small quantities, prepacked or non-prepacked), use of home kitchen, as well as implementation choices made at Member State level. A clear set of rules targeting the SSC along with other EU policy tools would help farmers better understand and fulfil their obligations and would provide consistent and structured support for these alternative sales channels.