GPSR and Your Vinyl Release: What EU Labels Actually Have to Put on the Sleeve

Somewhere between approving your test pressing and sending artwork to print, a question turns up that has nothing to do with music. Any record first sold in the EU from 13 December 2024 onward has to carry contact details for whoever released it. Not the plant that pressed it. You.

Most labels find this out late. Usually it arrives as a message from a distributor asking for a "manufacturer contact", or an empty field on a Discogs profile, or a line in an email from a shop. By then the sleeves have often already been printed.

This guide assumes your label is based in the EU, which covers most people reading it. If you're releasing from outside the EU, there's one extra step, covered further down. Either way, it isn't hard to meet. It is easy to miss, and annoying to fix once 300 jackets are sitting in a box. Here is what it actually asks for.

What GPSR is

GPSR stands for General Product Safety Regulation, formally Regulation (EU) 2023/988. It replaced the older EU product safety directive and has been fully in force since 13 December 2024. It covers consumer products sold in the EU, and there is no carve-out for music. Bandcamp said as much when the rules landed: vinyl, CDs, apparel and posters all count as consumer products.

Before anyone panics, some context. This regulation was written with complicated things in mind. Toys with small parts. Electronics with batteries. Furniture that can tip over onto a toddler. A record sits close to the bottom of the risk scale, and the practical obligations reflect that. What you mostly owe is information, not testing.

Who counts as the manufacturer

This is the part people get wrong, and it is worth slowing down for.

Under GPSR, "manufacturer" does not mean the company that physically made the object. It means whoever puts the product on the EU market under their own name or trademark. For a record, that is the label. If you self-release, it is you.

The plant that pressed it is a subcontractor, as long as it's pressing to your spec and not selling records under its own name. They made your record the way a printer makes your posters: to your spec, under your name. They are not the party the regulation is looking for, and in our experience they will not raise it with you either, because it is not their duty and there is nothing in it for them.

That last row is us, so we will be direct about it. We manage the project: sourcing, files, timeline, test pressing sign-off, reference-copy checks, delivery. We do not become the manufacturer, and you should not let anyone talk you into printing a service provider's company details on your sleeve as the contact. Whoever's name and address is on there is the party regulators, shops and customers will come to. That should be the label.

What actually has to be there

Three things.

Who you are, and how to reach you. A name, a postal address, and an electronic address. "Electronic address" means something a person can write to and get an answer from, so a monitored inbox or a working contact form. A phone number on its own does not count. Neither does a bare web address with no route to a human.

Something that identifies the release. A type, batch or serial number, visible and legible. Good news here: you likely already have one. Your catalogue number can do this job, as long as it uniquely points to that specific release. If you're pressing more than one variant under the same catalogue number, a black run and a splatter run, say, or two different colourways, add a short suffix so each one is its own identifier. For a single, unambiguous pressing, nothing new to invent.

Somewhere it can be found. GPSR sets an order of preference: on the product first, on the packaging if the product genuinely can't carry it, in an accompanying document if neither works. A record's own surface is tiny and the run-out groove is already spoken for, so the sleeve is the practical answer for most releases, and it's where the information already sits alongside the credits that are printed there anyway.

What this looks like on an actual sleeve

Small print on the back, in the same block as the catalogue number and the copyright line. Roughly like this:

1. Catalogue number. Doubles as the product identifier. You are already printing it.
2. Name and postal address. The party behind the release, in a form someone could actually write to.
3. Electronic contact. An inbox you read, or a site with a working contact page.

A website address on its own does not satisfy the postal-address requirement, even if the site has a working contact form. The postal address and the electronic address are two separate items on the list, and both are expected. In practice this usually just means a short postal address sitting next to the catalogue number, with an email or a contact-page link right beside it for the electronic side. If a distributor is involved in your release, ask them before you finalise artwork. Under a written mandate they can act as your authorised representative and add their details next to yours, which gives you a professional contact point; it does not take your own name and address off the sleeve, and it does not happen just because they happen to be handling the release.

Your online listing counts too

The same information has to be visible to a buyer before they pay, not only on the object once it turns up in the post. The full list is your manufacturer contact details, a photo of the release, the identifier that points to that specific pressing, and any relevant safety or handling information. For a record, most of that is already sitting there anyway, a photo and a catalogue number are standard listing content, so the manufacturer contact is really the piece that's new.

Discogs built a field for exactly this. Sellers look for "Manufacturer Contact" on a label's profile, and if it is empty they have to go and chase somebody to fill it in. It's worth filling in, and it takes about two minutes, but it lives on your label profile rather than the individual release listing, so treat it as a good habit rather than the whole answer and put the same details on the listing itself too. Bandcamp put the responsibility on sellers and said plainly that they will not act as anyone's responsible person. If you sell from your own webshop, the same expectations apply there.

If you self-release and have no company

Here is the awkward one, and it deserves a straight answer rather than a shrug.

If you put a record out under your own name with no company behind it, you are the manufacturer as an individual, and the contact has to be real. Nobody wants a home address printed on three hundred jackets and then catalogued on Discogs forever. That reaction is completely reasonable, and it is a common sticking point.

A website on its own doesn't get around this, even with a contact form on it: the postal address is a separate requirement from the electronic one, and both are expected. The routes labels are actually taking:

• Use a postal address you're comfortable keeping public for years, home, a mailbox service, a bandmate's studio, alongside a monitored email or contact-page link for the electronic side. If it's a mailbox or business-address service, check first that they actually allow the address to be used this way and that mail sent there reaches you.
• Release through a label that's genuinely putting the record out under its own name, not one lending you its address while you stay the real releaser.
• Have a distributor formally act as your authorised representative, with a written mandate. That gives you a professional contact point on the sleeve, but it does not take your own details off it: the regulation keeps the manufacturer's name and address on the product, and the representative's details go alongside them. It is a defined role, not something that happens just because they're distributing the record, so confirm it with them directly.

Whichever you pick, settle it before artwork goes to print. It is a five minute conversation at spec stage and a reprint bill afterwards.

If the label is based outside the EU

Then you need a responsible person established in the EU: a named entity, formally appointed for the job, usually your EU importer or an EU-based authorised representative acting under a written mandate from you. A fulfilment service handling your shipping can fall into this role too, but only as a last resort, if there's genuinely no importer or representative already in the picture. It cannot be a marketplace you happen to sell through, and it cannot be established in Great Britain. Northern Ireland is a separate case, since GPSR applies there too under the Windsor Framework, so a responsible person based in Northern Ireland works just as well as one in the EU. For a lot of GB-based labels this has meant leaning on their EU distributor or appointing a representative directly. That sits in addition to your own details as manufacturer, not instead of them, both need to appear. It's also one of the quieter reasons an EU pressing and an EU point of contact make life simpler if your buyers are here, which is a different question from whether to press at all or go on demand.

Labels already based in the EU don't need a separate responsible person. But "your own details are enough" means the full set, name, postal address and electronic address, not a website on its own.

The paperwork nobody mentions

Article 9 also asks manufacturers to run an internal risk analysis and keep technical documentation: a general description of the product, plus whatever is relevant to judging whether it is safe. That documentation has to be kept for ten years after the release goes on the market, not an approximate figure.

For a record this is realistically about one page. What the item is, what it is made of, who made it, the obvious hazards (a 12" disc is rigid and has an edge, shrink wrap and polybags near small children), and how they're handled. If your plant can tell you what the vinyl compound and inks are, that's worth folding in too, since it's exactly the kind of thing an authority might ask about. It exists so that an authority can ask and you can answer. It's a paperwork obligation rather than a lab test, and a vinyl record sits close to the bottom of the risk scale, so what's proportionate to write down is short, but the file should be real and kept somewhere you can find it.

What GPSR does not ask for

Worth listing plainly, because a good share of the panic is about things that are not in there.

• No CE mark on your sleeve.
• No independent lab certification of the record on its own, though your risk assessment and technical file still need to be real if anyone ever asks.
• No registration anywhere. There is no GPSR database to sign up to.
• No relabelling of what's already out. Copies already placed on the EU market before 13 December 2024 can keep being sold as they are, that's about units already in circulation though, not a standing exemption for the catalogue number if you repress it later.
• Nothing from your plant, as long as they're pressing to your spec under your name.

Before your artwork goes to print

This is the point where all of it is still free to fix.

• Decide who the manufacturer is, in one sentence, and write it down.
• Have a postal address and an electronic contact that will both still work in three years.
• Put the details on the sleeve, in with the credits.
• Check the catalogue number is on the artwork and readable.
• Put your manufacturer details on the actual release listing, not just your Discogs label profile.
• If a distributor is involved, confirm their legal role and whose details they expect to see, before the artwork is final.
• Keep the risk assessment and technical file somewhere you can find it for the next ten years.

The logic is the same as test pressing sign-off. There is a moment after which changes stop being free. For the audio, that moment is approving the test pressing. For the sleeve, it is sending the print file.

Questions we get asked

Does GPSR apply to a run of 100 records?
Yes. The regulation does not set a minimum run size. It applies to consumer products sold to customers in the EU, whatever the quantity.

Is the pressing plant responsible for GPSR compliance?
No, as long as the plant is pressing to your spec and not selling records under its own name. The manufacturer is the party placing the product on the EU market under its own name, which for a record is the label or the self-releasing artist. The plant is a subcontractor, in the same position as your printer.

Can I put my website on the sleeve instead of a postal address?
No. The regulation asks for a postal address and a separate electronic address, an email or a working contact form. A URL only covers the electronic side, not the postal one. In practice labels keep both as short lines next to the catalogue number. If a distributor formally acts as your authorised representative, their details go on the sleeve alongside yours, not instead of them: the manufacturer's name and address stay on the product in every case.

What if I self-release and do not have a company address?
You are the manufacturer as an individual, and a postal address is still required, a website alone doesn't cover it. Common routes are a postal address you're comfortable keeping public for years, sometimes through a mailbox or business-address service (check first that it actually allows its address to be used this way and reliably forwards mail), releasing through a label that's genuinely putting the record out under its own name rather than just lending it. A distributor acting as your authorised representative under a written mandate adds a professional contact point, but their details sit next to yours rather than replacing them, so it does not solve the address question on its own.

Do older records need this?
Specific copies already placed on the EU market before 13 December 2024 can keep being sold as they are, without being relabelled. That's about units already in circulation though, not a standing exemption for the catalogue number if you press a new run later.

Does Microcut Studio act as the manufacturer or EU responsible person?
No. We manage production: sourcing and comparing plants, preparing files, holding the timeline, getting test pressing sign-off, reference-copy checks and delivery across the EU. The manufacturer role, and everything that comes with it, stays with the label releasing the record.