From the 13th December 2024, the European Union’s General Product Safety Regulations (GPSR) 2024 will come into force, affecting all products “placed on the EU market” after that date. These regulations are far wider reaching that previous regulations (such as those that require some types of products to carry a “CE” mark), and instead it is notable that all products are included except if specifically excluded. That means books now come under its ambit. Although books sold to customers in England, Wales and Scotland do not fall within this legislation, it is worth noting that books sold to customers in Northern Ireland do fall within it, due to Northen Ireland’s presence within the EU Single Market. There appear to be different opinions about what constitutes “placed on the EU market” but all books published after that date will definitely be included if sold into the EU; books published prior to that date are less clear but if copies are printed after that date could be seen as included so it is wise to be prepared for that.
What does it mean for books sold into the EU?
The key requirements of the legislation are:
- There should be an EU Responsible Person in place for all products sold into the EU. A Responsible Person is a person or business based inside the EU who can take responsibility for safety queries and issues
- All products should be marked with a unique identifier and batch information allowing any faulty issues to be traced back, as well as details of the Responsible Person, the Manufacturer and (where appropriate) any safety information
- Manufacturers need to perform safety assessments on their products and keep clear documented records of any safety issues
- Online sales platforms need to have key information available to customers – the EU Responsible person, any safety information, and details of the manufacturer
Do I need to appoint an EU Responsible Person for my books?
If Bookvault are the exclusive printer of your books (at least, for sale in the EU) you do not need to do anything. Bookvault has appointed East Access System Europe (EAS), based in Tallinn, as its Authorised Representative and EAS will perform this function for all books printed by Bookvault and shipped into the EU. Bookvault will in due course be adding these details plus Bookvault’s own details onto any books printed by Bookvault, alongside the other critical information that is already there (for example, the ISBN as a unique identifier, and the barcode in the back that can carry production batch information). EAS are also performing the safety assessment required for your books, so with that this should ensure your books remain compliant with EU requirements
What if I use other printers for my books too?
If you are selling books printed by other printers, it may be that they will have EU Authorised Representatives appointed you can use for those titles, though you will need to make it clear which Representatives relate to which titles on any eCommerce sites. However, another option is that you appoint your own EU Representative – if you wish to do that, many businesses provide that service, and Bookvault would be happy to provide an introduction to EAS if you wish to use their services. Alternatively, you can contact them directly on gpsr@easproject.com. If you do use a different EU Representative to EAS, it’s important you notify Bookvault so both Bookvault and EAS’s records can be updated. For now, Bookvault are using the assumption that unless told otherwise, any books Bookvault print will have EAS as the EU Responsible Person
What is happening for books sold in the EU via Amazon, eBay, AbeBooks etc?
Critically, Amazon and eBay have declared that titles that are not compliant will be removed from EU websites (note, not Amazon.com or Amazon.co.uk) from 13th December. Where Bookvault are selling via The Great British Bookshop marketplace stores, Bookvault are working to ensure all relevant information is with Amazon to ensure sales continue without a hitch, but it is important to tell Bookvault if you intend to have your own EU Authorised Representative so they can update records for your titles.
If you (a publisher or author) are selling yourselves via Amazon, eBay or AbeBooks, whilst the requirements for each site differ slightly, the critical things you may need to do are:
- Upload the Authorised Representative details
- Upload the Manufacturer details
- Update any compliance documentation requested, including (where requested) a Declaration of Conformity in the language of any particular website)
- Complete any other attestations online as required
Here are guidance links for Amazon and eBay:
https://help.easproject.com/how-to-add-gpsr-data-to-amazon
https://help.easproject.com/adding-gpsr-information-to-ebay-listings
Your first step may be to check the health of your listings in your Seller Central account – that will indicate if Amazon or eBay believe actions need to take place to preserve your listings. Over the coming weeks it would be wise to keep checking the account in case of changes.
Note, if you sell on Amazon yourself and have also enrolled your titles for wholesale distribution via Bookvault, please do check the Amazon Brand Registry and ensure that The Great British Bookshop is set up as a registered seller for your books. That will help Bookvault ensure your titles remain available through that channel, as it removes any potential issue between compliance information you have uploaded and that uploaded by Bookvault.
What should I do about my own eCommerce website?
If you sell via your own eCommerce site (e.g. Shopify) then technically the same details should be visible on your own website as is being requested by Amazon or eBay. Obviously, you do not have the threat of site availability being removed from 13th December, but you do run the risk of not being compliant from that date.
What are the EU Responsible Person and Manufacturer details?
For books printed by Bookvault, you can use these details:
Manufacturer details:
Copytech (UK) Ltd, Trading as Printondemand-worldwide.com
9 Culley Court
Orton Southgate
Peterborough
Cambridgeshire, PE2 6WA
United Kingdom
01733 237867
EU GPSR Authorised Representative:
Easy Access System Europe Oü, 16879218
Mustamäe tee 50, 10621, Tallinn, Estonia
gpsr.requests@easproject.com
+358 40 500 3575
What is a Declaration of Conformity?
Some eCommerce websites are asking for a Declaration of Conformity to be uploaded against a product record – this Declaration should be in the language of the website in question (e.g. French for Amazon.fr and Spanish for Amazon.es). Again, check your eCommerce websites to see where they are requesting this data; if you need them, versions of the form in different languages are available here for Bookvault printed products:
How do I update the Amazon Brand Registry to ensure The Great British Bookshop is a registered seller?
The page used to add sellers can be found in the seller account menu, but this link may help: Amazon. Once you have accessed the Brand Registry you can add all the following tokens (non-EU ones are included in order to ensure consistent supply across all markets):
Amazon US, Canada and Mexico: A5809S5V6JIEJ
Amazon Australia: AOGFBRMQ56FED
Amazon EU and UK sites: A2U321JN96E0UZ