General Product Safety Regulation (GPSR) – Publisher Compliance Guide

 

1. What Is the GPSR?

The General Product Safety Regulation (EU) 2023/988 replaces the previous General Product Safety Directive and strengthens product safety, traceability, and accountability requirements within the EU.

Although traditionally associated with physical goods, GPSR also applies to digital content distributed in the EU market.

If you use a distribution platform to sell or distribute your content in the EU:

• You are considered the manufacturer

• You bear full responsibility for compliance

• You must ensure product safety and traceability

 

 

2. Your Responsibilities as Manufacturer

By distributing content to the EU market, you acknowledge that you are the manufacturer under GPSR.

As the manufacturer, you are solely responsible for compliance with all applicable safety and labeling requirements.

Your obligations include:

 

3. Risk Assessment

You must conduct an appropriate risk assessment of your content to identify potential safety concerns.

This includes evaluating:

✔ Content Harmful to Minors

• Explicit or age-restricted content

• Sensitive themes requiring clear classification

✔ Flashing Images or Seizure Risks

• Visual effects that may trigger photosensitive epilepsy

• Rapid flashing, strobe effects, or intense motion

✔ Age Restrictions

• Proper age categorization where applicable

• Clear warnings in metadata

✔ Potentially Harmful Instructions

• Technical, medical, financial, or practical instructions

• Content that could cause harm if misapplied
  
  
  
  

Risk assessments should be documented and updated when content changes.

 

 

4. Technical Documentation & Traceability

Manufacturers must maintain clear technical documentation demonstrating compliance.

You must retain:

• Records of content creation and modification

• Documented risk assessments

• Compliance verification records

• Batch or version tracking information

This ensures traceability if authorities request compliance verification.

 

 

5. Product Identification & Contact Information

Each product made available in the EU must include clear identification.

You must provide:

✔ Unique Product Identifier

• ISBN or other unique identifier

✔ Manufacturer Identification

• Your name or registered trade name

✔ Postal Address

• A physical address where you can be contacted

✔ Electronic Contact Information

• Email address or website

This information must appear:

• In the product metadata, and

• Where applicable, within the content itself (e.g., copyright page)

 

 

6. Responsible Person (If You Are Outside the EU)

If you reside outside the European Union:

You must:

• Appoint a responsible person located within the EU

• Provide the responsible person’s contact details in product information

• Ensure the responsible person can cooperate with EU regulatory authorities

The responsible person acts as a regulatory contact within the EU.

 

 

7. Record Retention Requirements

You must retain compliance documentation for a minimum of:

📅 Ten (10) years

after the product is made available on the EU market.

This includes:

• Risk assessments

• Technical documentation

• Traceability records

• Compliance confirmations

Authorities may request this documentation at any time within the retention period.

 

 

8. Practical Steps for Publishers

To ensure GPSR compliance:

1. Implement a formal risk assessment checklist

2. Standardize copyright page identification details

3. Ensure ISBN and metadata consistency

4. Maintain version tracking for updates

5. Store compliance documentation securely

6. Establish a retention policy for 10 years

 

 

9. Consequences of Non-Compliance

Failure to comply with GPSR may result in:

• Product withdrawal from the EU market

• Regulatory investigation

• Fines or penalties

• Mandatory corrective measures

Compliance is a legal obligation for all manufacturers distributing within the EU.

 

 

10. Summary

If you distribute content in the EU, you are considered the manufacturer under GPSR and must ensure:

✔ Proper risk assessment

✔ Maintained technical documentation

✔ Clear product identification and contact details

✔ EU responsible person (if located outside the EU)

✔ 10-year record retention

 

GPSR strengthens accountability and ensures that all products — including digital content — meet EU safety standards.