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GPSR for Books and Printed Materials: Do You Need Compliance?

Do books fall under GPSR? Physical print books are in scope but low-risk. E-books are out. Children's books with toy elements are the real catch. Here's what applies.

EUProof7 min read
Stack of hardcover and paperback books on a wooden table next to a children's picture book

If you sell books into the EU, you have probably read two flatly contradictory things. One blog says books are exempt from the General Product Safety Regulation. The next says print books are squarely in scope. Both are kind of right, and that is exactly why it is confusing.

Here is the short version. Physical print books are covered by GPSR, but the safety bar for them is low, so for most titles your real obligation is small. E-books are out entirely. The thing that trips up sellers is not the book at all. It is the toy glued to the cover, the crayon set in the box, or the plastic gift taped to the magazine.

Are books actually covered by GPSR?

The cleanest answer comes from the platforms enforcing it. Amazon's seller guidance lists "print books" by name among the products GPSR applies to, alongside used, repaired, reconditioned, and handmade goods. The e-commerce compliance firm BitsAndAtoms says the same: GPSR "applies to all non-food consumer products, including used, repaired, reconditioned, handmade, print books, and spare parts."

So the scope question is settled. Physical books are consumer products, and consumer products fall under GPSR.

Where the "exempt" claim comes from is the risk side. The logistics provider Spatial Global put it well: "Generally, publications, books and other printed materials are not considered 'consumer products' in the context of GPSR. Therefore, they are not subject to the safety requirements... but it's a very confusing message, so there may be exceptions." That captures the real-world feel of it. A novel does not choke a toddler or leach lead. The obligations exist, but they are minimal because the hazard is minimal.

The practical takeaway: do not assume "exempt" and skip everything. Assume "in scope, low-risk" and do the small set of things that matter.

What actually applies to a plain print book

Three things, in plain terms.

A Responsible Person in the EU. For physical books sold into the EU, the publisher usually acts as the EU Responsible Person. Waterstones spells it out: "For books, which are considered a low safety risk within their intended use, the EU Agent is typically the publisher or their authorised agent, such as an importer or distributor. Contact details for this agent must be provided on the book itself or its packaging." If you publish your own work, that agent is you, and you need someone established in the EU to fill the role. See our guide to the Responsible Person for who can hold it and what they have to do. (EUProof does not provide the Responsible Person service itself, so plan to arrange one separately.)

Contact details on the product. The agent's contact has to appear on the book or its packaging. A digital address counts, so an email or a specific website may be enough. The point is that a buyer or market surveillance authority can reach someone accountable for the product.

Basic safety with non-toxic materials. A German Amazon seller forum post made the point that print books are not risk-free in production: "Print-Bücher haben nichts von solcher Gefährlichkeit verloren: Toxische Materialien bei der Herstellung: toxisches Papier, Druckerfarbe, Klebemittel" — toxic materials in production, meaning paper, printing inks, and adhesives. In practice, if your printer uses standard, non-toxic inks and glues, the risk is low and the obligation is mostly to be able to show you used safe materials. A light-touch risk assessment documenting that is reasonable and cheap.

That is it for a normal book. No CE mark, no lab testing, no thick technical file.

E-books are out of scope

Good news for digital publishers. GPSR only applies to physical products. As Ingram IQ put it directly: "Does the GPSR apply to ebooks? No, it only applies to physical products."

So e-books, downloadable PDFs, digital patterns, and audio files you sell as files are not covered. The moment you sell a printed, bound, shipped object, you are back in scope. If your catalogue is mixed, the same title can be in scope as a paperback and out of scope as a Kindle file. For the wider rule on digital goods, see GPSR for digital products.

The real trap: books that are part toy

This is where most book sellers get caught, because the risk does not live in the pages.

Children's books increasingly come with attached plush, plastic figures, sound modules, or interactive parts. Those elements create real physical risks: choking on small parts, toxicity from coatings, sharp edges. Penguin Random House describes its own process plainly: "For any of our children's products that contain toys or toy elements, those elements are risk-assessed, and safety tested for such things as choking hazards and toxicity."

The compliance firm Euverify draws the line as a two-track system: "Toy books must comply with the Toys (Safety) Regulations 2011, while all other books fall under the General Product Safety Regulations 2005." Those are the UK provisions, but the EU principle is the same. In the EU the toy track sits under the Toy Safety Directive (2009/48/EC) and the general track under GPSR (Regulation (EU) 2023/988). Different obligations, depending on whether the thing in your buyer's hands is a book or a toy.

A few common cases:

  • A board book with a soft plush handle. The book is low-risk; the plush element gets toy-grade testing and likely CE marking and EN 71 testing.
  • A magazine with a plastic toy taped to the cover. The magazine is low-risk; the toy attachment may need CE marking and EN 71 testing on its own.
  • A coloring book bundled with crayons. The book is low-risk; the crayons are a separate chemical product that has to meet REACH and GPSR rules, including non-toxic labeling and safety data.

The pattern is the same every time. Split the product into its parts. The printed part stays low-risk. Any toy or chemical part is assessed and tested on its own terms. The CE marking and EN 71 obligations on a toy element come from the Toy Safety Directive (2009/48/EC), not from GPSR itself. For the relationship between GPSR and CE marking on those toy elements, see GPSR vs CE marking.

Even a children's item that is clearly a book and not a toy still does not escape the regulation. Euverify again: "Even if it's not a toy, it still needs to follow the General Product Safety Regulation, which applies to all consumer products." Low-risk is not no-rules.

What this means for self-publishers and resellers

If you are self-published and using print-on-demand, you are the manufacturer. You need a Responsible Person in the EU. Sometimes your printer or distributor with an EU presence can act as one, but get that confirmed rather than assume it. Publishers have been moving on this since the deadline: Troubador Publishing announced that "from December 2024, Troubador Publishing Ltd (and The Book Guild Ltd) will be GPSR compliant." If you sell direct on a Shopify store or through a marketplace, the same logic applies to you.

If you resell second-hand or antiquarian books, you are technically in scope. Used products are covered. Enforcement here is light and the original manufacturer may no longer exist, which makes it a real gray area. The pragmatic move is to be reachable and honest about condition, not to chase paperwork for a 1960s paperback.

The audience this regulation actually worries is the small seller who reads "books are exempt," relaxes, then ships a children's activity book with a whistle in the back. The book was fine. The whistle was the product safety problem.

If you want to figure out exactly which parts of your catalogue need documents, our Am I Affected tool walks you through it in a couple of minutes, and the GPSR compliance checklist covers the steps for the products that do need work.

This article is general guidance, not legal advice. Confirm your obligations with a qualified advisor or your Responsible Person.

Frequently asked questions

Does GPSR apply to my self-published print-on-demand book?
Yes. If you publish it, you are the manufacturer under GPSR. You need an EU Responsible Person unless your printer or distributor with an EU presence acts as one. Some print-on-demand platforms with an EU entity may take that role, but confirm it in writing rather than assume.
Do I need an EU address printed on the book itself?
Effectively yes. Waterstones states that contact details for the agent must be provided on the book itself or its packaging. A digital address such as an email or specific website is generally accepted, but the contact has to be reachable and on the product.
Are antiquarian and second-hand books covered?
Yes, used and reconditioned products are in scope, though enforcement is low. Amazon sellers have raised concerns about old books and CDs where the original manufacturer no longer exists. This remains a gray area in practice.
What about magazines with a free gift like a plastic toy attached?
The magazine itself is low-risk, but the toy attachment falls under toy safety rules. Under the Toy Safety Directive (2009/48/EC), the toy may need CE marking and EN 71 testing. The printed part and the toy part are assessed separately.
Does GPSR apply to coloring books with washable crayons?
The book component is low-risk. The crayons are a separate chemical product that must comply with REACH and GPSR, including safety data and non-toxic labeling. Bundling them does not make the crayons exempt.

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