Edit: This blog post is probably directed more for a corsetiere / corset seller to understand how GPSR may affect their business and subsequently make decisions that are right for them. If you are a corset wearer who primarily buys corsets (not sells them) this will still be helpful for you to understand the gravity of the new regulations.

Corset consumers: The best way to know if a corset brand is still shipping to Europe is to MESSAGE THEM AND ASK. If said corset brand does not know anything about GPSR or they’re not taking it seriously, take it as a red flag. The repercussions of ignoring the new regulations, from what I’ve read, could be anywhere between “the package gets refused at the border” to “the seller receives hefty fines for non-compliance” and as of yet, we still have no idea where it will fall.

I will preface this by saying I’m not a lawyer. Corset sellers – whether independent corsetieres or OTR brands – ought to seek out a lawyer for specific advice, or another specialist who deals with this topic specifically (like services offering to act as the Authorized Representative for other brands).

This week I learned that the General Product Safety Regulation (GPSR) mandates are moving forward in the EU.

Starting December 13, 2024, they require that all non-European businesses (that includes me!) who market or ship to EU countries, need to have an “Authorized Representative” (an importer or other responsible person) physically living in the EU.

The “Authorized Rep” needs to understand your business and your products. They will very likely need to have a good knowledge of what corsets are made from, and how each part functions. (They need know what steel bones and grommets are, coutil and other fabrics, and explain why each part is needed and not superfluous). This is more than just a pair of socks.

This person acts as the contact guy, the liaison between you and the GPSR authorities, and they need to prepare all your paperwork in case there are product recalls, for example. The Authorized Rep (which I’m going to abbreviate as AR for my own sanity) is essentially saying “I am a European citizen who will take responsibility to ensure the safety of the products being imported, and I will be personally liable in case any customer gets injured from your product.”

Here is the first snag. The folks working at these AR services may only have a surface level knowledge of corsets, and they may believe the harmful misinformation constantly perpetuated by laypeople who are naive to the true utilitarian history of the corset and corset-adjacent orthopedic support devices.

Obviously I do not believe corsets to be inherently harmful (as I’ve said countless times over the past 14+ years). But I do think people are capable of using them incorrectly in any number of stupid ways that may cause injury to themselves, whether or not instruction manuals are provided. Nevertheless, AR services have the right to refuse representation of corsetieres and their brands for this reason alone.

Because we don’t know how much information they need, how expensive it’s going to be, etc, I suspect that many independent corsetieres will simply stop selling to the EU.

What exactly is required of brands?

For those of us hoping and considering to keep serving our European audience, we are still not clear on what exactly needs to be included in or on the packaging. Again I’m not a lawyer, and I won’t even claim to fully grok this subject. But here’s my best guess about what the requirements might look like, going from easiest to hardest (based on conversations with other corset brands, and the articles I’ve read on GPSR in general):

• Easiest: on the box, mailer or bag: extra labels or stickers with the address, email and phone of the Authorized Rep.

• Inside the box/packaging: a manual showing safety warnings, instructions for proper and safe use. This instruction manual has to be written in the mother tongue / official language of that country, so corsetieres might have a translated print-out in one language, specifically for that one customer in that one country. Or OTR brands might make a multi-language instruction sheet containing all the languages of the EU countries they ship to. How much information they need, we have no idea. Is it simply enough to provide common-sensical instructions like “pull the laces just snug, not painful” or do we need to say “contains metal, DO NOT touch your car jumps to the grommets” ?
• Batch numbers associated with your corsets – obviously if your corset is one of a kind, you will not have batches of corsets – however, you may be required to keep a record of the lot number of your coutil or silks, and the batch of bones you purchased from one store or the batch of grommets you bought from a different store. Just in case there was a “bad batch”, you need to be able to trace it back to which batch of grommets went into which corsets, and contact those customers directly in addition to having your AR write up a public recall notice.
• Information about the intended end user (i.e. an adult over the age of 18 or 21 or 25, depending on how hardened the corsetiere wants their bones to be, how developed their prefrontal cortex, and how responsibly they presume their customer to behave). If this is the case for enforcing the “intended end user”, there might even be extra requirements like paying extra to get an adult signature before the package is delivered.
  But how far do we have to go to prove that we are primarily marketing to adult consumers? Will they enforce that we need to put an age restriction on accessing our websites? The corsetry community has already been accidentally caught in the crossfire of online censorship making it harder to advertise or market our garments (especially after FOSTA-SESTA laws passed). There is a big difference between “we sell a garment that is designed for an adult to wear, much like Depends underwear is marketed for adult incontinence” vs “we are all about that sessytimes and general debauchery”.
• Technical documentation about your product with “risk analysis”. If you have done any tests on your products to test its safey (for example, a high heel brand having done maximum weight tests) then you need to include this documentation.
This needs to be from the manufacturer – so if you are a corsetiere that makes everything, you are that manufacturer. If you are an OTR brand that outsources manufacturing, then you need to ask your manufacturer to provide this documentation.
Any possible risks posed to the safey of a customer needs to be written up, explaining what you have done to mitigate these risks.
  For example, what if a bone breaks in your corset? You can explain that under normal use this is not supposed to happen, but IF a bone does break, what have you done to minimize any risk to the customer? A super tightly woven fabric that resists tearing perhaps, the nylon-dip coating might sort of “hold” the bone together like a greenstick fracture instead of shattering, or (thinking back to Fakir Musafar, Ruth Johnson, and Michael Garrod) perhaps the application of rubber cement over the bone itself to “seal” the whole thing and prevent any movement within the boning channel. (But the rubber cement may have its own risks.)
  What happens if the grommets tarnish on a corset that’s been soaked, or left in damp storage for 10 years? We mitigate this by plating the grommets with a less reactive metal, but we would still have to discuss the sort of risks would be associated with an old corset that has some corrosion staining, etc.
  What risks, if any, associated with the fusibles or the starch or the sizing in the fabrics itself?
  These technical documents are to be kept by your AR for at least 10 years after it has been introduced to the market, with the promise that the maker will keep them up to date if you make any changes to your corset (I have heard this could be as subtle as changing the fashion fabric, but again I don’t have verification).
• Hardest: possibly individual sew-in labels for the corsets. Will GPSR insist on the sewn-in labels of the corsets to be in the official language of that country?
If the GPSR insists on knowing all contents of a corset, is it fine to say “steel, cotton, silk, polyester” etc, or do they need to go into extreme detail of all the possible chemicals involved?
  Like bones: nylon dip coating over spring steel, galvanized electroplated spiral steels, uncoated stainless steel, or in the case of synthetic whalebone, “Polyethylene Terephthalate (PET) Type 1 plastic” (I do not actually know if synthetic whalebone is PET, don’t come at me) and for any corsetieres who use this, do they need a certification from their supplier/manufacturer that it contains no BPA or PFAS?
  Same with the textiles (polyester, silk, cotton, etc) especially if vinyls become a banned substance due to growing concerns of its environmental impact, potential hormone-mimicking properties, or microplastic bioaccumulation.

Again, because it’s hard to say how deep the rabbit hole goes in terms of how to be fully compliant, I am fully unsurprised that some corset makers (especially in North America) are choosing to say “no thanks” to even trying at all. But it’s important to mention that these requirements are going to be similar for any non-food, non-medicine, and non-antique-art product. So whether you sell hair scrunchies, or stationery, or corsets, they will ALL need an instruction manual and safety warnings.

What about Article 51?

There is also a part of the GPSR document called Article 51 which (allegedly) states that any product that was previously shipped into the EU before Dec 13th 2024, it will be “grandfathered in” and essentially be allowed to continue being imported after the new regulations take effect. However, there is no specific info on how the authorities are going to enforce or check this for every pacakge. Will we need to register a list of product SKUs and provide receipts from previous orders, proving that those items specifically were sent to Europe? Will that registered list be in the database of the EU / GPSR authorities, or will it be the responsibility of the Authorized Rep to keep this list (in which case we still need to find an AR to handle this, no way around it?)

Will this exemption extend to all general product types, so as long as it is a corset made with generally the same materials and same use, all future corsets will be protected under the same umbrella guidelines? (Even if a different color of brocade is used, for example.) This would be useful for bespoke corsetieres who make one-of-a-kind items and may not even have a SKU system. But if these new regulations require SKUs (or worse, a GTIN), corsetieres are stuck – Article 51 would not apply to them and they will need to learn how to comply with the new regulations.

And as I said before, even before considering all these compliance practices, we need to be able to find an Authorized Representative first. Corset makers are at the mercy of these AR services, and whether they have any pre-existing biases against the safe use of corsets in general.

Then there are the financials

Looking into the pricing options for some of these AR and import services, I have seen anywhere between $200 and $1750 USD per year and that is for relatively low volume, for example for a one-off import, or up to 10 imports per month. If a corset maker has a $50 take-home profit on a $300 corset (after materials, labor, shipping, income tax, etc) and sends maybe 5 corsets to the EU per year (meaning they keep $250 of their European sales), then paying $200 annually for representation may simply not be worth the expense and hassle of setup & maintenance. In fact, I have already started seeing announcements from small corset businesses / independent corsetieres who they have simply decided to stop selling to the EU.

If corsetieres do take on the task of ensuring they’re compliant, there is a question as to whether they will spread out those extra fees globally over all of their customers, or only their European customers, so I wouldn’t be surprised if prices rise.

On the other hand, any struggling corsetieres within the EU who have previously not been getting enough business from local clientele, this may be their saving grace as customers are less likely to purchase from outside the EU and more likely to support their local businesses (which, not to sound obtuse, but is probably exactly the point). (And you can find local corsetieres via my corsetiere map HERE!)

Oddly enough, a corsetiere in the EU has the deep working knowledge of corset contents and uses, and would be in good position to pivot into a new role as THE go-to Authorized Rep for other corset makers around the world. (Likely a retired corsetiere rather than still active, depending on the time constraints). That is, IF they are willing to take on that responsibility / potential liability. That is a BIG IF, though.

TL;DR it’s a mess, and everyone is confused.

There is new info coming out about this every day, and it appears no one has a straight answer.

There is rumored to be more info coming out specifically targeted towards independent artists and small businesses on what compliance specifically looks like (as compared to bigger conglomerates) but that info will only come out after Dec 13, which feels a little too late.

Any folks who have a better understanding or more information about how GPSR will affect corset makers, or other small creative businesses in general, I invite you to share your thoughts.

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