EU Regulation 2023/988 General Product Safety Regulation (GPSR)
The General Product Safety Regulation (GPSR) is a new set of EU rules, which require all consumer products in EU markets to be safe, and establish specific obligations for businesses to ensure product is compliant. The regulations come into effect 13th December 2024 and apply to books, journals and other printed items intended for sale in the EU. You can view the full GPSR document here
Our understanding is that as a publisher you will firstly be required to keep copies of GPSR certificates of conformity for your suppliers on record. You can find our certificate in this link.
You will also need to EITHER appoint an EU Authorised Representative or you can use Gomer’s designated EU Authorised Representative EAS.
Changes to imprint pages are also required as details of the publisher and printer will no longer be sufficient. Specific details for an EU Authorised Representative will also be required. So the text would be something like;
Publisher: Example Publisher, London, UK
Printed and bound by : Gomer Press, Llandysul UK
EU Authorised Representative: Contact details for the EU AR (provided on request if you wish to use Gomer’s designated EU AR)
This information may also need to go on delivery notes and carton labels depending of the specific requirements of your distributors.
ISBN/SKU details will be held on file with the EU AR, and book compliance details will also have to be registered with sellers such as Amazon.
Books are inherently safe items and our understanding is that the EU currently has no enforcement mechanisms at all for this product type.
If you do choose to use Gomer’s AR it is important to mention that in the unlikely event of a safety concern being raised to them, there will be a charge made to resolve the concern as there would be with any AR. Further details are available on request.
The further information below is largely drawn from the UK Government website;
Summary of the Regulations
The regulations require that all products placed into the EU and NI markets are safe and establishes specific obligations for businesses to ensure that safety.
Attention should be brought to the following Articles:
Article 3: Definitions.
These define what is considered as a safe product and who is responsible for complying.
• ‘Safe Product’ (Article 3.2) means any product which, under normal or reasonably foreseeable conditions of use, including the actual duration of use, does not present any risk or only the minimum risks compatible with the product’s use, considered acceptable and consistent with a high level of protection of the health and safety of consumers
• ‘Manufacturer’ (Article 3.8) means any natural or legal person who manufactures a product or has a product designed or manufactured and markets that product under the person’s name or trademark.
In this instance the book publisher is the ‘manufacturer’ and is responsible for ensuring that their product is ‘safe’.
Article 9: Obligations of Manufacturers.
We would recommend that you familiarise yourself with this section as it will help you understand what internal steps you may need to take.
In summary manufactures need to:
• ensure that a product complies with the general safety requirement as outlined in the regulation before placing it on the markets.
• Carry out a risk assessment and keep a technical file for the product.
• Ensure that the product can be identified by consumers in an easily visible and legible way. The ISBN and impression number would suffice.
• Indicate your name, postal and electronic address.
• Indicate the contact details for your Authorised Representative** – this could be a link to a webpage, but it must be reasonably straightforward for the consumer to identify from that link how to make contact. Your Authorised Representative will be able to supply the correct information and wording for you to use.
• Where a product cannot be safely used as intended without it, ensure the products are accompanied with clear instructions and safety information.
• Where a manufacturer believes a product, it has placed on the market is dangerous, it shall immediately:
i. Take necessary corrective measures to bring the product into conformity
ii. Inform affected consumers of the corrective measures
iii. Inform the relevant Market Surveillance Authorities
**Publishers, individuals or any business that wish to sell their product into the EU or NI market must appoint an Authorised Representative as set out in Article 10. Your Authorised representative would assist with any quality issues, product recall and the Market Surveillance Authorities.
Article 10: Obligations of authorised representatives
1. A manufacturer may, by means of a written mandate, appoint an authorised representative.
2. An authorised representative shall perform the tasks specified in the mandate received from the manufacturer. The authorised representative shall provide the market surveillance authorities with a copy of that mandate upon request. The mandate shall allow the authorised representative to perform at least the following tasks:
(a) providing a market surveillance authority, upon that authority’s reasoned request, with all information and documentation necessary to demonstrate the safety of the product in an official language which can be understood by that authority;
(b) where the authorised representative considers or has reason to believe that a product in question is a dangerous product, informing the manufacturer thereof;
(c) informing the competent national authorities about any action taken to eliminate the risks posed by products covered by their mandate through a notification in the Safety Business Gateway, where the information has not been already provided by the manufacturer or upon instruction of the manufacturer;
(d) cooperating with the competent national authorities, at their request, on any action taken to eliminate in an effective manner the risks posed by products covered by their mandate.
Information required
Your current imprint page may contain a lot of the required information, but to ensure that your product is fully compliant with the regulation please consider including the following information:
• Publisher name and address
• ISBN
• Publication date
• Impression number
• Details of printer
• EU Conformity Declaration
• EU Authorised Representative – full contact information or text as supplied from them
Publishing new titles and reprints
The new regulations will impact all new titles being printed that are destined for the EU or NI market, but it will also be important to remember that any reprints are updated with the correct imprint page.
We can help you update your print files where required and we are here to help you in any way we can.
If you do wish to discuss the changes please feel free to contact us on sales@gomer.co.uk or get in touch with your Account Manager.
Useful links:
https://www.gov.uk/government/publications/eu-regulation-2023988-on-general-product-safety/eu-regulation-on-general-product-safety-2023988
https://www.gov.uk/guidance/trader-support-service