Can Ingram serve as my EU Representative?
If books are not printed by Lightning Source, Ingram cannot serve as the EU Authorized Representative.
If an EAN is printed exclusively by Lightning Source, there is a compliance URL available that provides contact info for Lightning Source to serve as the EU Authorized Representative.
If LS 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. This website URL will also be printed on each book directing the consumer/ agency to this information. LS will also be adding its mailing address for each manufacturing site on the last page.
Compliance url: https://www.ingramcontent.com/pod-product-compliance
Will there be an extension to provide the necessary GPSR details?
From our understanding, we are already in the grace period, which ends December 12, 2024. Any other timeline would be retailer-specific based on their inventory levels etc.
Can you provide more details about the requirements?
The information required comes directly from the GPSR specifications. You can find the background via the links provided below.
Will my titles be delisted if I do not provide the necessary GPSR information?
This decision will be up to individual retailers as to whether they will carry products based on vendor compliance with GPSR. In future, Ingram may choose not to export products missing GPSR information into the EU.
What if I do not have an EU-based contact for my products?
There are several third-party companies within the EU who provide these services. Please seek legal guidance for additional information.
Do resellers accept all GPSR fields in ONIX?
Most resellers are still not accepting ONIX 3.1, which contains the current GPSR standards. Ingram will provide the necessary information in a separate file to relevant EU resellers where ONIX is not possible.
Where can I learn more about GPSR and ONIX?
ONIX 3.1.2 was just released in late October. You can also learn more from a recent BISG webinar.
When will Ingram be ready to ingest ONIX 3.1.2?
Development is under review. We will share an ETA when we have one available.
We have several printers that we use. Does that mean I need to fill out a form for each printer?
Our understanding of the regulation is that there must be a contact for each product manufacturer. Ingram will accept as much information as you can provide on the Jot Form at this point and you can continue to add more information.
Will Lightning Source be the responsible party/contact for its POD books?
Yes, for the POD units manufactured by LS.
Does the GPSR apply to ebooks?
No, it only applies to physical products.
More Information About GPSR
The General Product Safety Regulation (“GPSR”) will apply to all products that are (i) imported to, or (ii) made available within, the European Union (“EU”) market as of December 13, 2024. The GPSR establishes requirements related to a product’s design, manufacture, and placement to help ensure products do not pose a risk to consumers. Product manufacturers, suppliers, distributors and wholesalers will all be affected by this new regulation. As it pertains to books and other products sold by Ingram Content Group (“Ingram”) into the EU, the GPSR will apply to Ingram, as well as the suppliers (including publishers) and manufacturers (including printers) of such books and other products. As the distributor of these products, Ingram will need to rely on its suppliers (including publishers) to meet the compliance requirements.
Applicability
The GPSR applies to:
- Suppliers and Manufacturers: Both EU-based and non-EU-based suppliers and manufacturers placing products directly on the EU market or making products available to be placed on the EU market.
- Importers and Distributors: Must verify that products comply with the GPSR before distributing them.
- Online Marketplaces: Responsible for ensuring that products sold on their platform meet safety standards.
Compliance Requirements
To comply with the GPSR, at minimum, those to whom the GPSR is applicable must:
- Conduct Risk Assessments: Identify and mitigate risks associated with their products.
- Technical Documentation: Maintain detailed documentation proving product safety in compliance with the GPSR.
- Clear Labeling: Provide safety information and warnings in the languages of the EU Member States where the products are sold.
- Traceability: Maintain records to trace the origin of the products and ensure they can be recalled if necessary.
- Responsible Person: Designate a responsible person within the EU to ensure compliance and act as a contact point for product safety issues.
You can review the full GPSR document here: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R0988
To ensure compliance with the GPSR, you should seek independent legal guidance.