Does the GPSR apply to books and printed products?

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Jason van de Zande

Yes, the General Product Safety Regulation (EU) 2023/988 (GPSR) can apply to books and printed products when they are placed on the market or made available to consumers in the EU. Most standard books are low risk, but the GPSR still acts as a safety net where no more specific EU product safety law applies. The key questions are when a printed item creates a real safety hazard and what documentation, labelling, and EU Responsible Person duties apply to non-EU sellers.

Does the GPSR cover books and printed products sold to consumers?

The GPSR can cover books and printed products because it applies broadly to consumer products placed on, made available on, or offered on the EU market. A printed book, poster, sticker set, or notebook can be a “product” if it is supplied to consumers, including via online sales.

In practice, many printed items present minimal safety risks, but the GPSR still applies as a general framework. Where a sector-specific EU harmonisation law (lex specialis) covers a product’s safety aspects, that specific law takes priority for those aspects, and the GPSR fills the gaps.

The GPSR is about product safety, not the legality of the content (for example, copyright, hate speech, or advertising rules). Content regulation and consumer product safety are separate topics, even when they relate to the same physical item.

When can a book or printed item become a GPSR safety issue?

A book or printed item becomes a GPSR issue when its physical design, materials, or foreseeable use can create a risk to health and safety. This is most common for children’s products, novelty formats, or printed items with added components.

  • Chemical hazards: inks, dyes, coatings, laminations, glues, and plasticisers that can transfer through skin contact or mouthing.
  • Choking and ingestion risks: detachable parts in pop-up books, sound modules, magnets, stickers, or decorative attachments.
  • Cut and puncture hazards: sharp corners, exposed staples, wire binding, or metal fasteners.
  • Flammability risks: certain paper treatments, foams, textiles, or plush add-ons used in “book plus” products.
  • Electrical risks: books with lights, batteries, charging ports, or electronic sound features.
  • Borderline toy classification: if play value dominates, toy safety rules may apply alongside, or instead of, a general printed-product approach.

A practical way to manage this is to carry out a risk assessment based on normal and reasonably foreseeable use, paying special attention to vulnerable consumers such as children. Other EU rules, such as REACH restrictions on certain chemicals, can apply in parallel with the GPSR.

What GPSR obligations apply to publishers, brands, and online sellers of printed products?

Publishers, brands, and sellers must ensure that only safe products are made available in the EU, and they must be able to show how safety is ensured when authorities ask. GPSR obligations apply across sales channels, including distance selling and online marketplaces.

  • General safety requirement: design and supply products that are safe under foreseeable conditions of use.
  • Traceability and identification: keep product and operator details clear so units can be traced through the supply chain.
  • Contact details: provide the required economic operator contact information on the product, packaging, or accompanying documentation, as applicable.
  • Warnings and instructions: provide safety information when needed, including for children’s use cases and any special handling.
  • Technical documentation: keep documentation proportionate to the risk, such as material specifications, supplier declarations, test reports where relevant, and a risk assessment.
  • Cooperation with authorities: respond to requests from market surveillance authorities and support corrective actions, including withdrawals and recalls when required.
  • Accident handling: monitor safety feedback and take appropriate corrective measures if an accident indicates a safety problem.

Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), products covered by the GPSR that are supplied by a manufacturer outside the EU must have an EU-based Responsible Person (an economic operator established in the Union). Online marketplaces often check for this information during listing or compliance reviews.

How does EARP help with GPSR compliance for books and printed products?

At EARP, we help you determine whether your books or printed products fall under the GPSR, which risks matter for your format, and what your EU economic operator setup must look like to maintain EU market access.

  • Confirm GPSR applicability and identify any lex specialis rules that may also apply
  • Map your role as manufacturer, importer, distributor, or fulfilment service provider for EU sales
  • Provide EU Responsible Person services for eligible products
  • Review labelling and required contact details for the product, packaging, and listings
  • Check and store technical documentation, and make it available to authorities upon request
  • Act as your liaison with market surveillance authorities and support corrective action planning

See our GPSR compliance services, or contact us to discuss your printed products and the fastest path to meeting GPSR requirements.

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