Books, print products and packaging inserts

• Regulation (EU) 2023/988 — GPSR
• Regulation (EC) No 1907/2006 — REACH for inks and coatings
• Directive 2009/48/EC where the product is a children's book with toy elements
• Regulation (EU) 2025/40 — packaging where applicable

Who has to appoint one

Publishers and print businesses outside the Union placing physical print products on the EU market. Ordinary books raise few safety issues, but children's books with attached toys, sound modules or bath books are treated differently and can fall under the Toy Safety Directive.

Thresholds and exemptions

None under GPSR. The toy classification applies where the product has play value for children under 14, which covers cloth books, sound books and books with attached figures.

What must appear on the label

Manufacturer and responsible person details with an EU address, and where the product is a toy, CE marking, age marking and the Annex V warnings. Battery-powered sound modules bring the battery markings and producer registration.

Marketplace fields

Marketplaces apply the responsible person requirement to books as to any other physical product, which surprised many publishers when the GPSR fields went live.

Documentation you must hold

Technical documentation proportionate to the risk, REACH evidence for inks, laminates and coatings, and for toy-classified products the safety assessment and EN 71 test reports.

Standards and testing

EN 71-1 for small parts and mechanical hazards, EN 71-3 for migration from printed surfaces a child may mouth, and REACH screening for phthalates in plastic components and for primary aromatic amines in inks.

Language requirements

Any safety warnings in the language of each member state of sale. The content of the book itself is not regulated by product law.

When it applies

Before the product is made available.

How long records are kept

Ten years.

What happens if you do not comply

Listing suppression and withdrawal. Children's books with detachable parts have generated Safety Gate alerts, and sound modules with accessible button cells are treated as a serious risk.

Who enforces it

Market surveillance authorities and customs.

Where the boundary lies

Button cells are the critical hazard: since the battery rules tightened, products with accessible coin cells face specific requirements and have been recalled repeatedly. A book with a sound module is simultaneously a print product, a toy and an electrical product with battery obligations.

Questions we are asked

Do books need a responsible person?

Yes, as physical consumer products placed on the EU market, and marketplaces enforce the field for books like any other category.

Is a cloth book for babies a toy?

Generally yes, with CE marking and EN 71 testing, because it has play value for a child under 14.