The limits are primarily related to EU Type Approval and the impact that towing has on other aspects of the car's behaviour and performance, and rarely a structural limit. I've run into this with other cars, where the US versions have a massively higher towing limit than the EU cars, despite having the same structure. Some of it seems to relate to differences in crash testing, but Toyota were clear that their restrictions were wholly related to fuel consumption when I tried to get more information. They claimed (no idea if it was wholly true) that if they allowed a tow hitch to be fitted to EU market vehicles then the impact of towing had to be included in the overall performance/efficiency testing. The Prius can be fitted with a hitch in the US, but not in the EU (except for two specific and limited exemptions, one in The Netherlands, one in Germany). The fitments are on the UK spec cars, and fitting the US hitch is a ten minute bolt on job, but as with the Tesla Model 3, there's an EU Type Approval problem that prevents the fitment of a hitch as an after market add-on.
My experience with getting hitches fitted to various cars over the years has been that things are massively more relaxed in the US, with after market receiver hitches being available for pretty much any car ever sold there. Very often cars that are sold here that cannot (legally) have a hitch fitted are fine with one in the US, plus the US load limits are a great deal higher. Many states in the US (not sure about Canada) require some form of registration/licensing for trailers and campers, and that often includes specified weight restrictions, both train weight and tongue weight. One interesting thing I discovered when exploring the legalities of fitting a hitch was that, despite the very much tighter EU Type Approval requirements, there aren't any fewer towing accidents here than there are in the US, in proportion to miles driven. It seems that we have this additional legislative burden for no really good reason.