The EU’s New General Product Safety Regulation (GPSR): What Book Publishers Need to Know

The EU’s new General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, came into effect on December 13, 2024. This law replaces the 2001 General Product Safety Directive, modernising the EU’s product safety framework and addressing challenges posed by digitalisation. The GPSR applies to all consumer products sold in the EU market, including physical books, e-books, and other digital products, ensuring they are safe for consumers.

What is GPSR?

GPSR establishes essential safety rules for consumer products sold or made available on the EU market. It ensures a high level of consumer protection while improving the internal market’s functioning.

A “safe product” is any product that, under normal or reasonably foreseeable conditions of use, doesn’t present risks or only minimal risks deemed acceptable for consumer health and safety. The regulation applies to physical and digital products sold in the EU, including the European Economic Area and Northern Ireland. It impacts businesses worldwide that sell to the EU.

How GPSR affects Book Publishers?

Under GPSR, book publishers, including e-book creators, are considered “manufacturers” responsible for ensuring their products meet the regulation’s safety requirements. While print media is generally low risk ensure they meet the crucial GPSR requirements for books. 

Conduct a Risk Analysis 

Publishers must assess any potential hazards associated with their books, whether physical (e.g., materials used in printed books) or digital (e.g., e-books containing embedded links to harmful sites).

Create technical Documentation 

Publishers are required to maintain technical documentation for each product. This should include descriptions of the book’s characteristics (e.g., physical, mechanical, or chemical properties for print books) and, where relevant, safety measures for digital products.

To simplify this process, we offer a technical file template specifically for book publishers. This reusable template significantly reduces the effort required to comply, helping publishers meet documentation requirements quickly and efficiently.

Product Marking for Traceability 

Books must include product markings for traceability, such as the book type, batch or serial number (e.g., ISBN and print-on-demand barcodes), and relevant identifiers for e-books.

Include Contact Information 

Publishers are required to include their name, registered trade name or trademark, postal and electronic address on the book or its packaging. If the manufacturer is not established in the EU, the name, postal, and electronic address of the responsible person within the EU must also be included. This means publishers must have an authorized representative within the EU, even if the publisher itself is not based in the EU.

Provide clear instructions and safety information 

Publishers must ensure their books are accompanied by clear instructions and safety information if necessary for the safe use of the product. For example, if a book contains content that could pose a risk, especially for children, specific warnings or information should be provided. E-books might require disclaimers about suitable devices or access risks.

Maintain an Internal Register of Complaints and Recalls 

Publishers are required to maintain an internal register of complaints, product recalls, and any corrective actions taken to bring products into conformity. This register should include details of the risk to consumers' health and safety, any corrective measures taken, and the quantity of products still circulating in the market, if available.

Challenges for Book Publishers 

The introduction of GPSR presents several challenges for book publishers, particularly for independent publishers, bookshops, and self-published authors.

Confusion and Lack of Clear Guidance 

There is widespread confusion about the implications of GPSR for the book industry. Many publishers and bookshops are unclear about what specific actions they need to take to comply. Guidance on GPSR has been described as “sparse” and “vague,” particularly concerning the required documentation.

Finding an Authorized Representative 

Publishers selling into the EU but not based in the EU must appoint an authorized representative within the EU to handle communication with authorities on product safety issues. However, finding a suitable representative can be challenging, and the pricing for this service varies greatly, ranging from “quite reasonable to exorbitant.”

Updating Backlist Titles 

Updating backlist titles to comply with GPSR can be challenging, particularly for independent publishers with limited resources. Physically labeling existing stock to meet the new requirements, if necessary, could be costly.

E-Commerce Compliance 

E-commerce platforms, including Amazon and eBay, require publishers to provide Declarations of Conformity for each product sold in the EU. Publishers must ensure these declarations are uploaded to their online stores to avoid their products being delisted from European sites. This requirement adds an extra layer of administrative burden for publishers.

Impact on Self-Published Authors 

Self-published authors are significantly impacted by GPSR. They may lack the resources to meet the requirements, such as conducting risk assessments and creating technical documentation. This could lead to some authors having to stop selling their books in the EU.

How EU Compliance Partner can help 

EU Compliance Partner can act as your authorized representative in the EU, ensuring your books comply with GPSR. We understand the complexities of the new regulations and can guide you through the process, making it easier for you to continue selling your books in the EU market.

For just $200, we provide:

• Technical File Template: Our template is tailored for book publishers, allowing you to quickly prepare the necessary documentation with minimal effort.
• Authorized Representative Services: We will act as your EU-based authorized representative, handling communication with EU authorities and ensuring you meet the necessary requirements.
• Risk Assessment and Technical Documentation: We can assist you with conducting a risk assessment for your books and preparing the required technical documentation. Our team has expertise in product safety regulations and can ensure your documentation meets EU standards.
• Product Marking Guidance: We will provide clear and concise guidance on correctly marking your books with the required information for traceability, ensuring you meet labeling requirements.
• Imprint Page and Packaging Updates: We will help you update your book’s imprint page and packaging to include the necessary contact information and any required safety warnings.
• E-commerce Compliance Support: We can assist you in preparing and uploading Declarations of Conformity for your books on major e-commerce platforms, ensuring your products remain available for sale in the EU.

Don’t risk losing access to the EU market because of GPSR. For a low annual fee of just $200, we can help you navigate the complexities of the regulation, ensuring your business remains compliant and your books can reach readers across the EU. 

Contact us today to learn more about our GPSR compliance services for book publishers. Our team is ready to answer your questions and provide the support you need to confidently sell your books in the EU.