Please note this article does not represent legal advice. It is meant to serve as a guide. We recommend you consult your legal counsel with any questions you may have about this topic.
TL;DR: The GPSR does not apply to either ebooks or online courses.
Here is an excellent resource on this topic:
Here's a screenshot & quote from that post:
"Does GPSR impact eBooks or digital goods?
No, GPSR only applies to physical goods. This means eBooks and other digital products are not affected by the regulation. If you primarily sell digital formats like Kindle eBooks or PDFs, you don’t need to worry about GPSR compliance.
However, if you sell physical books alongside your digital offerings—such as paperbacks or special edition hardcovers—you’ll need to ensure those physical products meet the GPSR requirements. The regulation specifically targets items that are manufactured, shipped, and sold as physical goods in the EU, leaving digital content entirely out of its scope."
A General Observation About Current Precedent
We have a service where we self-publish books through Amazon KDP for Leanpub authors. These books are sold both in ebook format and print format through Amazon from their marketplaces around the world.
As of this writing (April 29, 2025), we have not noticed them asking us for anything to do with the GPSR in that regard.
A quick search shows Amazon has GPSR rules for "Sellers Members", however.
Our understanding of this is that it applies to people who are Amazon sellers who are selling physical books on Amazon that they provide to Amazon themselves.
Some Details About the GPSR and EU Regulation
The GPSR began applying to people from December 13, 2024.
It appears to be meant to protect people from harms from physical goods:
" (1) Directive 2001/95/EC of the European Parliament and of the Council (3) lays down the requirement that consumer products must be safe and that Member States’ market surveillance authorities must take action against dangerous products as well as exchange information to that effect through the Union Rapid Information System (RAPEX)."
The GPSR document itself doesn't seem to define "product", but that is defined elsewhere in official documentation (related to the EU Data Act) this way:
"The term ‘product’ is defined as a tangible, movable item, including where incorporated in an immovable item, that obtains, generates or collects data concerning its use or environment, and that is able to communicate data via a publicly available electronic communications service, and whose primary function is not the storing and processing of data".
Insofar as the GPSR appears to apply to "digital content", it uses language about "tangible medium", like this:
"Article 14 of Directive (EU) 2019/770 of the European Parliament and of the Council (20) also applies in terms of the tangible medium, such as DVDs, CDs, USB sticks and memory cards, used to carry a digital content."
Note that "Services" are specifically excluded:
"(17) Services should not be covered by this Regulation. However, in order to protect the health and safety of consumers, products that are supplied or made available to consumers in the context of the provision of services, including products to which consumers are directly exposed during the provision of a service, should fall within the scope of this Regulation. However, equipment on which consumers ride or travel, where such equipment is directly operated by a service provider within the context of a transport service, should be excluded from the scope of this Regulation since it has to be dealt with in conjunction with the safety of the service provided."
Note that as with all regulation, it is subject to change and questioning, e.g.: Commission guidelines for SMEs under the GPSR.
Resources
The GPSR document is here:
Document 32023R0988
Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety, amending Regulation (EU) No 1025/2012 of the European Parliament and of the Council and Directive (EU) 2020/1828 of the European Parliament and the Council, and repealing Directive 2001/95/EC of the European Parliament and of the Council and Council Directive 87/357/EEC (Text with EEA relevance)
You can also find it here:
The EU Data Act-related document we looked at for the definition or "product" is here:
Opinion of the European Central Bank of 5 september 2022 on a proposal for a regulation on harmonised rules on fair access to and use of data (Data Act)
"The term ‘product’ is defined as a tangible, movable item, including where incorporated in an immovable item, that obtains, generates or collects data concerning its use or environment, and that is able to communicate data via a publicly available electronic communications service, and whose primary function is not the storing and processing of data"
You can read more about the Data Act here.
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