The following guidelines for publishers are in relation to the sale of printed magazines and books in the EU & Northern Ireland, produced in association Lewis Silkin LLP and Marketforce.

In light of the updated EU General Product Safety Regulation (GPSR), which came into effect on 13 December 2024, book and magazine publishers exporting to the EU, European Economic Area (EEA), or Northern Ireland (NI) must appoint an Authorised Representative based in the EU. 

This requirement applies regardless of the sales channel used, meaning all exports, including those made via third parties or online platforms, must comply. 

Background to the regulation 

The GPSR is a key instrument in the EU product safety legal framework. It replaced the previous General Product Safety Directive and the Food Imitating Product Directive from 13 December 2024. 

The GPSR requires that all consumer products on the EU markets are safe and establishes specific obligations for businesses to ensure it. 

A key requirement in the Regulation is for non-EU-based companies to have an authorised EU-based representative to act on behalf of the manufacturer/publisher and importer to provide a local contact for quick resolution to issues in the market with products. 

The legislation requires all product manufacturers to provide their authorised representative’s contact details (postal address and electronic address) on the printed products supplied into the EU market.  

If there is a ‘safety issue’, this can readily be reported via this representative and the product can be easily recalled from the market if required. All products must be ‘traceable’ – which for magazines and books can be done using ISBNs/Barcodes and Volume Numbers/Issue Identifiers. It is recommended that manufacturers/publishers retain an audit trail detailing production traceability for all products supplied to the EU for at least 10 years. 

How does this affect publishers? 

Book and magazine products distributed within the EU must comply with these requirements. This also includes products for sale in Northern Ireland. 

What needs to be done? 

Sellers should establish an Authorised Representative in the EU to act on their behalf in relation to GPSR 

Options: 

1. Use an existing EU-based entity as an authorised representative, or, 

2. Appoint a specialist third-party representative to specifically manage this process on behalf of the seller 

Responsibilities of an Appointed Representative include, but are not limited to: 

• The representative to be referenced on the product, for example on the imprint page of the book, as a point of contact for any safety queries/complaints raised. 

• The representative will also have to report to the authorities on any concerns with a product or actions taken to ensure a product’s safety (if required). 

• Regularly check that a product has had a relevant risk assessment drawn up for it (where relevant) and that it complies with various technical requirements (e.g. manufacturer’s name, postal and email address is included on the product, the product is accompanied by clear instructions/safety language). 

What is the recommendation? 

Appoint a specialist third party representative to manage the process and that help you fully understand the implications of EU GPSR. 

What is my next step? 

For titles yet to be printed, you will need to print details of the appointed EU AR on the imprint page of each magazine to be sold in the EU or Northern Ireland, alongside a safety declaration statement. 

What are the labelling requirements?  

It is advised to include on the magazine or book imprint page: 

• The business name, clearly stated as the ‘Manufacturer’ along with a contact email address 

• Clear heading advising ‘GPSR EU RP’ 

• The company name of the authorised representative 

• Their full postal address (EU based) 

• A contact phone number (EU based) 

• A contact email address 

• A declaration statement that avoids the need for additional paperwork or assessments given that books/magazines are deemed ‘safe’ 

What would the text look like? 

An example statement could look something like: 

“General Product Safety 2023/988: The use of our product 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, which are considered acceptable and consistent with a high level of protection of the health and safety of consumers” 

PLEASE NOTE – This declaration statement is an example only. It will need to be reviewed by each publisher’s own legal department and appointed AR to ensure it meets the full requirements of EU GPSR in the sale and distribution of their product within the EU and Northern Ireland. 

This information should all be included on the imprint page of each magazine and book available for sale within the EU and Northern Ireland. 

Risk assessments 

Despite printed products being ‘deemed safe’ there is still a requirement for your business to create and develop risk assessment documentation for all products sold within the EU (and Northern Ireland), if requested by EU regulatory bodies. 

Magazine products with cover mounted toys or gifts may come under more scrutiny than non-cover mounted variants, especially as the EU has proposed new toy safety rules. It is recommended that additional information is sought from your appointed AR to ensure compliance. 

What do I need to do online? 

All of the detail required in the ‘Labelling Requirements’ needs to also be available for consumers or regulatory bodies on the Manufacturer’s website, who in this case is the publisher. 

There is little clarity around how visible this needs to be on the website, but we would suggest that you add it. You may however be able to get away with including it as a link on the website footer alongside your existing Privacy Policies, Cookie Policies etc.