Why Can’t I Buy the Models I Want in the EU Anymore?

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Mike

As of December 2024, the European Union’s new General Product Safety Regulation (GPSR) has come into force, replacing the 2001 General Product Safety Directive. While the regulation’s primary intent is to ensure the safety of products sold within the EU, its far-reaching requirements are having a significant impact on small businesses — particularly those involved in the miniature wargaming industry. Many overseas suppliers are finding themselves unable to comply with the GPSR’s stringent demands, effectively cutting off EU customers from accessing their favorite wargaming miniatures and accessories.

What is the GPSR?

The GPSR was designed to modernize EU product safety standards and harmonize rules across member states. It imposes stricter obligations on manufacturers, importers, and distributors to ensure the safety of non-food consumer products. Key requirements include:

  1. Detailed Safety Documentation: Every product must come with a technical file documenting its compliance with EU safety standards, including risk assessments, traceability, and more.
  2. EU Representative Requirement: Non-EU manufacturers must appoint an EU-based representative to handle compliance and liability.
  3. Explicit Warnings: Products must clearly state their intended age range and provide warnings if they are not suitable for children under 14.
  4. Packaging and Labelling: Enhanced labelling requirements apply to ensure transparency about product materials, hazards, and intended use.

The Impact on Miniature Wargaming Companies

Miniature wargaming manufacturers — often small businesses or solo artisans — are struggling to adapt to the GPSR for several reasons. These sorts of regulations act as anti-competitive, non-tariff barriers to entry that prevent small businesses from entering and competing in the EU market, all under the guise of child safety. If your child is eating lead miniatures, you’ve got a bigger problem.

1. Prohibitive Costs

Complying with the GPSR’s requirements is expensive. For example, creating a technical file for each product involves significant time and expertise, often requiring third-party testing to meet safety standards. Appointing an EU representative adds further financial strain, as it involves legal contracts and liability coverage. For businesses operating on narrow profit margins, such costs are unsustainable.

2. Unsuitability for Adult-Oriented Products

Miniature wargaming products are explicitly marketed to adults, often with warnings such as “This is not a toy. For ages 14 and up.” The GPSR’s focus on child safety, however, means these products are treated as though they could be marketed to children. Many wargaming miniatures are made from materials like resin or pewter, which would fail testing under toy safety standards, despite being entirely safe for their intended adult users.

3. Administrative Burdens

Small businesses often operate with limited staff, and the administrative workload required to comply with GPSR regulations is staggering. Such compliance requirements are far more burdensome for a one-person company working out of a basement compared to large corporations like Games Workshop, which have dedicated legal teams and compliance budgets. This disparity underscores the challenges faced by small manufacturers trying to compete in the EU market.

4. Inaccessibility of EU Markets

For many overseas manufacturers, the cost and complexity of GPSR compliance make EU sales economically unfeasible. As a result, companies are choosing to stop selling to EU customers altogether. Shiny Games, a UK-based distributor, reported in their blog that even domestic resellers are reconsidering EU distribution due to the regulatory burden. And yes, let’s not forget that Brexit has exacerbated this mess. Thanks, boomers.

Of course, the EU continues to lead the world in regulation rather than innovation. I guess that’s the trade-off I get for a low cost of living and free healthcare, but I do miss the “anything goes” nature of the USA… well, at least before they started throwing tariffs around recently.

The Personal Impact: A Gamer’s Perspective from Gozo, Malta

As a miniature wargaming enthusiast based in Gozo, Malta, the GPSR has profoundly affected my hobby. I often purchase historical, fantasy, and sci-fi models cast in metal from independent manufacturers. These niche suppliers, who produce high-quality miniatures, often operate outside the EU and cannot comply with GPSR regulations due to the associated costs and complexities. This means I can no longer order directly from them and have items shipped to Malta.

For someone living on a small island, the only practical alternative is attending conventions in the UK, such as Partizan or Salute, and purchasing models directly. However, this comes with significant costs — flights, accommodation, and convention expenses quickly add up. It’s a luxury that many gamers cannot afford, making the regulation particularly restrictive for those in smaller EU markets like Malta. The loss of access to independent manufacturers also limits my ability to support the small businesses that bring diversity and innovation to the hobby. I can’t help but wonder if this regulation is also the reason some of my other orders haven’t made it through the mail yet.

Miniature Wargaming Suppliers and Compliance Status

Below is a list of suppliers affected by the GPSR, along with links to their statements about compliance or withdrawal from the EU market:

Suppliers Who Have Stopped Supplying the EU

Suppliers Who Have Complied or Resumed Supplying the EU

Please note that this list is incomplete and could change at any time as more manufacturers achieve compliance or learn about the regulations and post publicly.

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