GSPR and Readers / Customers in the EU

GSPR is new EU profuct safety regulation that comes into effect from 13th December. There are some great resources that have been put together on Patreon by Ripley Morgan (kudos!) which you can read here, but effectively my understanding is it means the following...

  • I'd need to hire someone based in the EU to act as my representative to EU authorities
  • I'd need to provide technical documentation on the product, potentially covering it's manufacture (inks used, paper used, chemicals involved, impacts of materials used to the environment and health)
  • Clear instructions on use of the product in all EU languages

Disclaimer

This is my understanding as of now based on the information which I've seen, much of which is vague. I'm risk averse and assuming the worst. Ultimately I think legislation on product safety is a good thing, and I don't disagree with GSPR in principle. It does seem designed for businesses within the EU with a large amount of resources, and not small business. For now the below is my understanding and my response to protect myself as an independent creator. If you're a small business or independent creator I strongly suggest you do your own research and assess your own business. Don't take this blog post as advice, it isn't. My intention is to make my position clear. I cannot sell Zines, Comics, or Artwork to you if you are based in the EU or Northern Ireland.

How this impacts my comics

None of this is really feasible for me as an independent creator. While I do make efforts to ensure I use printers who use responsibly sourced materials and safe, good quality inks, unfortunately I am very much at the mercy of a confusing and challenging market of printers who in my experience aren't particularly professional or reliable in their conduct. I am reliant on these suppliers, and I need to use them in good faith. I'm not sure this is worth the risk for me.

To sell comics (printed or digital) in the EU and Northern Ireland a Responsible Economic Operator in the EU is required to liaise with EU authorities and ensure all of my products meet the compliance criteria. For me personally, I am a single person makingmand selling comics outside of the EU. There's no way I could afford to hire someone based in the EU to act in this capacity for me. This is likely the case for most if not all independent comic creators and small press publishers.

I would also need to provide and maintain "technical documentation" for each comic or zine I sell. I have no idea what "technical documentation" means with respects to a PDF file or a printed comic. From what I've understood I'd need to provide information on the materials used to create the product and how sustainable they are. If anyone reading this has attempted to navigate the minefield of getting a comic book printed on a budget in the UK this is going to be a nightmare...

Printing comics in the UK

This is the bit that scares me the most. I may do a seperate blog post on printing comics in the UK as it's something I've been asked about a few times. 

I've had mostly negative experiences printing comics in the UK. Suppliers like Mixam are opaque and outsource on what seems to be a random basis. Getting technical information on the type of ink used, the type of paper used, the chemicals involved, recycling and sustainability, carbon impact etc would be a nightmare. 

I do know suppliers who specialise in comics, however my one experience with a specialist comics printer is after agreeing a quote I got ghosted for three weeks (phone calls would go straight to voicemail after one ring, I left several voicemails) and then getting an email saying "sorry I was on holiday I assume you got this sorted elsewhere". Considering how unreliable these services can be I don't trust them to be able to provide detailed technical information on inks and paper.

Digital comics

I can provide technical information on a PDF, but having worked as a web developer for a long time I know that different devices and different software configurations can be unpredictable and I don't want to take any risks with someone having a suboptimal set up. Without a representative in the EU it's not something I'm willing to do.

I would also need to provide clear instructions and safety information in all EU languages that are easy to understand. Instructions on reading a comic may be simple, but for a digital comic this could get more complex. How do you download a PDF? What software should you use? How does this vary by device or OS? Making comics is already very labour intensive, on top of marketing, research, developing my art practice, and managing a store this isn't something I can commit to. Also I'm not willing to trust translation software for covering all languages. This just isn't workable for me.

Unfortunately I can't fulfil orders to the EU or Northern Ireland for the foreseeable future. If in the unlikely event you're in the EU and you find me and take an interest in my work, I can't sell to you. Very sorry.

Conclusion

Honestly I'm just getting started with comics career, I've only been drawing comics for just over a year. My audience is small and I've never shipped comics to anywhere in the EU. I think someone in Northern Ireland once bought a digital comic on Gumroad from me (thank you!).

I do think product safety is important and thinking about the bigger picture and some of the awful practices you see on the larger online market places I can understand why the EU would introduce this legislation. It's a pain for me but if it protects consumers in the EU overall it's probably a good thing, if not fully thought through for small business.

I don't expect this to impact me significantly for now as I develop my practice and portfolio, it just limits the market I can sell too. It's a little bit scary as I know it impacts a whole load of my peers with more established audiences, and I'm hoping as things develop the guidelines become clearer. Thinking about rainbow and unicorn utopias I really hope the UK rejoins the EU sometime. I miss freedom of movement.

Good luck and much love!

Disclaimer

This is my understanding as of now based on the information which I've seen, much of which is vague. I'm risk averse and assuming the worst. Ultimately I think legislation on product safety is a good thing, and I don't disagree with GSPR in principle. It does seem designed for businesses within the EU with a large amount of resources, and not small business. For now the below is my understanding and my response to protect myself as an independent creator. If you're a small business or independent creator I strongly suggest you do your own research and assess your own business. Don't take this blog post as advice, it isn't.

Written by Bren on Thursday, December 5, 2024