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Börsenverein des Deutschen Buchhandels e.V.

Der Börsenverein des Deutschen Buchhandels ist die Interessenvertretung der deutschen Buchbranche gegenüber der Politik und der Öffentlichkeit.

Lobbying Activity

Response to Digital Fairness Act

24 Oct 2025

Börsenverein des Deutschen Buchhandels (the German Publishers and Booksellers Association) represents Germany's book sector in the political and public spheres. It was founded in Leipzig in 1825 and currently has roughly 4,000 members, which include booksellers, publishers, wholesalers and other media companies. As both a trade association and a cultural organisation, the Börsenverein works to promote books and reading whilst also fostering a fair legal framework. It also seeks to promote cultural diversity and uphold the right to freedom of expression. As representatives of many micro and SME businesses in the book sector, who contribute vastly to European digital economy, culture and democracy, while also facing significant challenges, we welcome the opportunity to provide input to the Digital Fairness Act (DFA). - Proper enforcement, not new obligations: Several important legislative instruments have been adopted over the past years (e.g. the General Data Protection Regulation, the Digital Markets Act, the Digital Services Act, the e-Privacy Directive, the Unfair Commercial Practices Directive and the AI Act) which already provide strong consumer protection. Before considering new legislation, the Commission should first strengthen implementation and enforcement to avoid disproportionate burdens on SMEs. Amid current geopolitical challenges, the Commission must uphold EU values and ensure continued enforcement of key legislation, particularly in areas like the DSA and DMA where compliance remains incomplete. - One size does not fit all: Not all sectors are comparable. For instance, on social media platforms, which are generally algorithm-driven and engagement-maximising, without editorial responsibility, certain features can contribute to problematic usage patterns, as targeted by the DFA. Conversely, cultural and creative works are professionally produced and editorially accountable, ensuring quality and responsibility in the content offered. It would therefore be more effective to focus enforcement on online environments, such as social media and big tech video sharing platforms, which are higher-risk environments, rather than applying broad, horizontal obligations across all sectors. Cultural goods, such as e-books and audiobooks, are inherently different from other products due to the way they are consumed: once accessed, they cannot simply be returned because a reader cannot unread a book. Considering that a digital book can be fully consumed within the normal withdrawal timeframe (14 days) it is reasonable that, once the download has been completed or streaming has begun, the withdrawal period for services (e-books and audiobooks) does not apply. This safeguard in the Consumer Rights framework must remain in place and be correctly enforced to avoid abuse. The book sector is deeply shaped by distinct business models, national cultural policies and specific regulatory frameworks. EU legislation should be flexible enough to take into account these sectoral and national specificities, avoiding a one-size-fits-all approach that could undermine existing, well-functioning systems and business models. - Address unfair practices by large platforms - dont make SMEs collateral damage: As a large proportion of actors in the European book sector are micro or small businesses, it is essential to keep their specific operational realities in mind. We fully support the aim to strengthen consumer protection and foster trust in European companies and the digital economy, however, we stress that measures must remain proportionate. At a time when Europes competitiveness is challenged and SMEs face an unprecedent load of new legislation to implement from the previous mandate, we urge the Commission to maintain a strong focus on consistent enforcement, proportionality, fairness, and support for SMEs, thereby ensuring a level playing field, while providing robust protection for consumers.
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Meeting with Nela Riehl (Member of the European Parliament, Committee chair)

17 Sept 2025 · Priorities of the German book sector

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

17 Sept 2025 · AI & Copyright

Response to A Culture Compass for Europe

30 May 2025

Sehr geehrte Damen und Herren, der Börsenverein des Deutschen Buchhandels ist der Spitzenverband der deutschen Buchbranche. Wir möchten die Entwicklung des Culture Compass for Europe mit unserer hier in der Anlage beigefügten Eingabe unterstützen. Bitte zögern Sie nicht, sich bei Rückfragen mit uns in Verbindung zu setzen. Mit freundlichen Grüßen Jessica Sänger
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Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

13 May 2025

Börsenverein des Deutschen Buchhandels e.V. (German publishers and booksellers association) fully supports the goal of ensuring legal clarity for operators, traders and surveillance authorities on the categories of products falling within the scope of the EUDR. As representatives of book publishers, we particularly welcome further clarifications regarding the exclusion from the scope of packing materials and packing containers and of accessory materials (namely marketing materials), when not placed on the market on their own. This exclusion should encompass items such as boxes used to keep together a series of books in a collection, which are distributed and sold together with the books; and point-of-sale advertising displays made of cardboard, which hold or accompany certain books, and are distributed with the books and can be reused. The relevant part of point 2(kk) in the annex to the draft Delegated Regulation could be integrated to this end to read used exclusively to support, protect, carry, hold together or display another product. Any other clarification aiming at the same goal would be beneficial. We also welcome the intention to further clarify the situation of waste, second-hand and used products with a view to encouraging circular and resource-efficient practices. Another specific feature of the book supply chain is the practice by retailers to return unsold books to publishers. These books are then destined to pulping (and recycling) or reintroduced into the commercial circuits. In both cases, they will have been already subjected to a complete chain of due diligence up until the retail stage. It would be disproportionately burdensome to keep goods at the end of their lifecycle, or unsold goods going back into commercial circulation to prevent waste, subjected to EUDR obligations well beyond a first completed chain of due diligence. We recommend integrating the relevant part of point 2(ll) in the annex to the draft delegated regulation to read not including used, second-hand and returned products. On a related note, we want to highlight the fact that books and other printed publications were not included in the original Commission proposal and therefore were not included in the EUDR impact assessment. The complexities for a sector that is so remote from the beginning of the supply chain and therefore was excluded from the EUTR have not been adequately assessed. The magnitude of the information requirements at the stage of book manufacturing and commercialisation is staggering and risks seriously disrupting supply chains, and possibly ending book imports altogether. Provisions such as allowing non-EU companies involved in supply chains to use the Information System to pass relevant data along to operators subjected to the EUDR is therefore essential. We also call for a sectorial dialogue with the Commission to address certain specificities of our sector.
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Response to Evaluation of the Public Procurement Directives

4 Mar 2025

Sehr geehrte Damen und Herren, der Börsenverein des Deutschen Buchhandels ist dankbar für die Gelegenheit, zur Evaluierung der vergaberechtlichen Regelungen Feedback zu geben. Unsere Mitgliedsbuchhandlungen begegnen im Schulbuchgeschäft häufig Schwierigkeiten, obwohl aufgrund der gesetzlichen Buchpreisbindung stets alle Angebote identische Preise enthalten müssen. Anbei übersenden wir Ihnen unsere Erläuterungen zum Thema mit der Bitte um Berücksichtigung.
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Meeting with Terry Reintke (Member of the European Parliament)

22 Mar 2024 · European Politics in general

Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

21 Feb 2024 · Stakeholder Roundtable on Late Payment Regulation

Meeting with Svenja Hahn (Member of the European Parliament)

14 Feb 2024 · Exchange on Late Payment Regulation

Meeting with Andreas Schwab (Member of the European Parliament)

23 Nov 2023 · Spielzeug

Meeting with Katrin Langensiepen (Member of the European Parliament, Shadow rapporteur)

22 Nov 2023 · Austausch zu Spielzeugsicherheit

Meeting with Christian Ehler (Member of the European Parliament) and Federation of European Publishers

21 Oct 2022 · Allgemeiner Austausch