Introduction

As of December 13th 2024, publishers wanting to distribute books to the EU need to be compliant with the new General Product Safety Regulation. This statement is designed to inform and reassure authors. Please note the information on this page has been collated after receiving advice from Softwood's EU authorised representative, ARC, and our print partners at Ingram, and​​ CPI, Europe's leading book printing company.

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What is GPSR?

From 13th December 2024, book manufacturers have an obligation to ensure that books of every kind are a designated “safe product”. The full GPSR document can be read here – https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R0988.

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The regulation defines “manufacturers” of products as:

“Any natural or legal person who manufactures a product or has a product designed or manufactured and markets that product under that person’s name or trademark”.

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Therefore, the publisher (or individual if self-publishing) is the “manufacturer” and has an obligation to ensure that their product (book) is a “safe product”, defined as:​

“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”.

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How can self-published authors meet GPSR compliance?

It is our understanding of the regulations that self-published authors will be defined as "manufacturers", as they "have a product designed" and usually market "that product under that person's name."

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Many self-published authors use publishers such as Softwood Books to distribute their books, whilst others use Ingram or Amazon directly, or both. Products placed on the EU market (including the European Economic Area and Northern Ireland) must have the contact details of both Manufacturer/Brand owner and the EU Responsible person present on the packaging. Since books are not supplied in packaging, this information must be contained in their imprint/copyright pages. 

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If publishers, and therefore self-published authors, wish to distribute their books to an EU market and are based outside the EU, then they must appoint an authorised EU representative who will act on their behalf in matters of compliance and communication with the regulatory authorities.​ Additionally, safety certificates from their printers must be obtained annually by the publisher and be held on record, along with proof of product insurance and a full risk assessment that meets GPSR requirements.​

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Self-published/independent authors only need to comply with GPSR if they ARE distributing or selling to the EU.

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Do print-on-demand distributors offer GPSR compliance?

Over December, more information has been released by major printers and distributors regarding compliance. Some companies will be able to provide GPSR compliance, others cannot, so authors will need to clarify with their printers if not using the likes of Ingram or Amazon. CPI cannot offer GPSR compliance, for example.

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It is our current understanding that if an ISBN is printed exclusively by Lightning Source (Ingram), there is a compliance URL available that provides contact info for Lightning Source to serve as the EU Authorized Representative. If Lightning Source is not the exclusive printer, LS cannot be the EU Authorized Representative, but the same URL can be used by the publisher’s designated EU AR if queries arise about a physical book that is printed via LS POD.

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Currently, the guidance from Amazon is unclear (see statement here) so we would recommend that authors who publish on both Ingram and Amazon KDP and/or a printed stock, and want to sell to the EU, seek their own compliance.

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How does Softwood Books meet GPSR compliance?

Softwood Books is compliant with GPSR as of December 2nd 2024. All titles produced by Softwood after December 13th 2024 will include Softwood's contact address and email (as the manufacturer) and the contact details for our EU Responsible Person. As this is being treated as a 'soft' launch, books that have been previously published with us won't require an updated imprint/copyright page until 2025. Our compliance ensures that all titles published through Softwood Books' imprint can continue to be distributed and sold in the EU after December 13th 2024.

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Can Softwood help authors like me continue selling books in the EU?

Softwood Books can support authors who publish on a variety of platforms and who wish to continue distributing to the EU, either by sending UK stock or through print-on-demand. In exchange for a one-off upload fee plus annual hosting charge that maintains GPSR compliance, authors can provide us with print-ready files for publishing. Authors do not need to have sought Softwood's production services in order to take advantage of our GPSR compliance.

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All current and future Softwood clients will be automatically registered as GPSR compliant if distributing to the EU.

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Please contact us directly at hello@softwoodbooks.com to discuss your title. Softwood does not receive royalties or claim ownership for any titles distributed by either Ingram or Amazon's print-on-demand service.

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