European GPSR: modifications to API ?

As per subject.
On december 13 all professional sellers selling in EU are obliged to pass any relevant information on the producer. (I know it's ridicoulus asking for the stamp or postcard producer issued on 1800/1900, but that's european world )

Delcampe have scheduled any update for this on API environment ?

I appreciate if mods can be explained here or on the github at least one month before december 13

Even then, 3 months is not a long time to collate all the required information for a business seller to remain compliant in the EU.

Thankfully not all products seem to require it (but I am not an expert). E**y's GPSR FAQ points to the following appendix that lists exclusions including antiques and stamps (thankfully for me) among other categories. Vinculo (https) . If not we'd be required to add warnings about paper cuts etc no doubt.

The requirement for a EU address for an authorised representative for each product sold in the EU is protectionism at its finest. If it is ever required my country ban list will grow to include the whole of EU. I've already banned half of the EU to avoid packaging fines of EUR1000+ as I'm unwilling to pay up to EUR150 per country for a packaging recycling licence in each country without a de minimis exclusion.

I think if you reread the faqs you will find that stamps that are currently valid for postage are included in the GPSR requirements. By the way not just the EU but also Northern Ireland is included because of the Windsor Agreement.
At the moment E**y seem to be taking a particularly hard line on GPSR by ignoring the exemptions & seeking GPSR info for all items. The promise/threat seems to be no info = no visibility.
As a result I am considering returning some stock to Delcampe but would like to hear what their policy is going to be before making any moves.
Any suggestions how I might find out would be welcome.

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Los datos ya no están disponibles porque la cuenta de este usuario ha sido eliminada (Reglamento RGPD)

Thanks for the correction, yes it looks like collectibles only, not stamps for postage. As I said I'm not an expert on this stuff!

I'm aware that NI counts as EU, the new Windsor agreement may add to our problems from the end of September. There may be customs formalities in all but name for sending packages to businesses (although how we are supposed to differentiate a stamp dealer from a regular customer is beyond me.

I'm seeing how things pan out but If i do end up having to block the EU it's likely the end of my delcampe store as well due to the numbers of exports here.

E**y have always taken the easy path with regulation (as there sanctions policies show with blanket bans). The majority of my sales are to mainland UK there thankfully.

I'm aware of what they are trying to catch and as with most beurocracies the net has been cast too wide.

We've had 20 years or so of relatively free international trade with a importer beware attitude.

The EU is going back to the days of customers only buying within your country/bloc. For those of us outside having to pay 500EUR per year per product for an authorised representative, then 2000 EUR for waste Is beyond most small manufacturers to sell directly. The best they can hope for is to close direct b2c sales and get a distributor to buy from them direct and sell on their behalf.

Hi everyone,

As stated by baltija, in the article 18 you can see that collectors’ items are out of the scope of this law and Delcampe is not concerned.

The complete content is available here : Vinculo (https)

Fred

Thanks Fred,

Unfortunately its probably not that simple as what is and is not considered a collectors item is set out by Customs Code within the legislation. Anything can be collected, and the EU does not want the 'collectible item' to be used as a get out clause, the legislation specifically states "that collectors’ items are of sufficient rarity and historical or scientific interest to justify their collection and preservation, and that antiques, if they are not already works of art or collectors’ items or both, are of an extraordinary age"

Tha majority of items listed on the site (e.g. postcards CN code 49090000, mint stamps for postage CN 49070010, and thats before you get to vynl records, books, etc) are not classified as collectors items within the legislation.

Supplies for collecting (which are also sold on your site) such as albums, stamp hinges, tweezers etc are not collectors items and will require GSPR information.

How will professional sellers obey the GSPR and continue to sell these items?

Following further reading, Article 51 (as below) probably covers most collectable items on the site which are already owned in the EU. I'm not sure how goods outside the EU at present are handled as I could see an argument that they are not on the EU market so not covered by this article.

It won't apply to goods sold as new from 13 December 2024 so Delcampe needs adjustments to continue to sell these items (or to cease allowing listings for them) as far as I can see.

Article 51

Transitional provision

Member States shall not impede the making available on the market of products covered by Directive 2001/95/EC which are in conformity with that Directive and which were placed on the market before 13 December 2024.

Hi stevehillstamps,

This was the Delcampe's legal department answer:
(16) The requirements laid down in this Regulation should apply to second-hand products or products that are repaired, reconditioned or recycled, that re-enter the supply chain in the course of a commercial activity, except for those products for which the consumer cannot reasonably expect that they fulfil state-of-the art safety standards, such as products which are explicitly presented as to be repaired or to be reconditioned, or which are made available on the market as collectible items of historical significance

(18) Antiques, such as works of art or collectors’ items are specific categories of products which cannot be expected to meet the safety requirements laid down by this Regulation, and should therefore be excluded from its scope. However, in order to prevent other products from being mistakenly considered as belonging to those categories, it is necessary to take into account that works of art are products created solely for artistic purposes, that collectors’ items are of sufficient rarity and historical or scientific interest to justify their collection and preservation, and that antiques, if they are not already works of art or collectors’ items or both, are of an extraordinary age. When assessing whether a product is an antique, such as a work of art or a collector’s item, Annex IX to Council Directive 2006/112/EC (13) could be taken into account.

And there is a definition of "antique" in the Article 3:
(28) ‘antiques’ means products, such as collectors’ items or works of art, in relation to which consumers cannot reasonably expect that they fulfil state-of-the-art safety standards.

Delcampe will close irrelevant items such as regular clothing or phone cases, but most of the items on the website can be considered as collector's items and are not concerned by the law

This subject is a bit out of my depth but I can ask for more clarifications to our legal department if you want.

Fred

Thanks for your response. I'm out of my depth with this stuff also.

A couple of specific cases for your legal department, all of the 2023 articles are on your site, the 2025 articles are likely to be once they are produced. These are deliberate edge cases to try and show the possible issues (IT testing background - sorry!). As a non expert, I've grouped the products into 3 results from the regulations. I hope to be corrected!

Not Subject to GSPR declarations due to being in a collectible customs code
- 2023 United Kingdom Used Christmas Stamp Set
- 2025 United Kingdom Used Christmas Stamp Set

Not in a collectible customs code, but not Subject to GPSR declarations due to article 151, and previously safe under previous GPSR regulations (but would these be subject to GSPR if imported from outside of the EU?)
- 2023 United Kingdom Mint Never Hinged Christmas Stamp Set
- 2023 Modern Postcard of Paris
- New Lindner Stamp Mount pack of 50 produced in 2023
- New Ultraviolet Lamp produced in 2023

Not in a collectible customs code, subject to GPSR Declarations
- 2025 United Kingdom Mint Never Hinged Christmas Stamp Set
- 2025 Modern Postcard of Paris
- New Lindner Stamp Mount pack of 50 produced in 2025
- New Ultraviolet Lamp produced in 2025

Los datos ya no están disponibles porque la cuenta de este usuario ha sido eliminada (Reglamento RGPD)

Hello SteveHillStamps,

By default, Delcampe considers collectors' items in the broad sense of the term to be outside the scope of the GPSR.

As a result, ‘2025 United Kingdom Mint Never Hinged Christmas Stamp Set’ and ‘2025 Modern Postcard of Paris’ will continue to be considered as collectors‘ items on our site, even if there is a risk of strict interpretation for certain member states (’When assessing whether a product is an antique, such as a work of art or a collector's item, Annex IX to Council Directive 2006/112/EC ( 13) could be taken into account").

With regard to new accessories produced starting 2025, we may have to prohibit their sale on the site in the future, especially if they are produced in China. This will impact
- New Lindner Stamp Mount pack of 50 produced in 2025
- New Ultraviolet Lamp produced in 2025

We will gradually adapt our Terms and Conditions, as for the following points already in force :

Electronic items such as computer hardware, telephony equipment and digital
photography equipment are only allowed if they meet all of the following criteria:
o they were manufactured over 10 years ago;
o they are used and have already been on the European Union market at least once;
o they are of historical interest or of interest to the collector.

Best Regards,

Christophe

Thanks Christophe, that makes sense. At the end of the day this will come out as states implement their controls.