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The CE mark has been a staple on numerous products since 1985 – it is a mandatory conformity mark and acts as a declaration from the manufacturer that their product meets all of the necessary requirements of any applicable EC directives relating to that product. Its presence (or perhaps, more notably, its absence) on labels is a clear indicator of quality to potential consumers.

At STAR, we would most commonly encounter this mark for products which meet the standards of the Machinery Directive 2006/42/EC, though there are countless other Directives which are part and parcel of the CE marking system.

When it comes to translating documentation for products that conform to the Machinery Directive, there are some important factors to consider – we’ll take a look at a few of the most frequently asked questions here:

 

What languages do I need to translate into?


The answer to this question depends on the countries in which you intend to market your products. Annex I, Section 1.7.4. of the Machinery Directive reads as follows:

All machinery must be accompanied by instructions in the Official Community language or languages of the Member State in which it is placed on the market and/or put into service.

Put simply, you need to translate your documents into the official language of each of your target markets.

However: Beware of thinking that you will only need 10 translations because you’re only exporting to 10 countries. Several countries within the EU have more than one official language – Finland, for example, classes Swedish as an official language as well as Finnish. Therefore, if you intend to conquer Finland as a market for your goods, remember that you must have your documents translated into two languages for that country, not just one. In this regard, it is best to do a little homework and find out which languages you may need to translate into in order to comply fully with the Machinery Directive.

 

Do I really need to translate every single item of documentation?


In short, it depends on type of documentation and the target readership.

As stated in the previous answer, the main rule is that all machinery should be accompanied by instructions in the appropriate language: by this, they mean operating instructions – the instructions a user would need to have in order to operate your machine. Naturally, they would need those instructions in their own language so that the machinery can be operated correctly and safely – there would be no guaranteeing this if the user was trying to figure out a language they didn’t fully understand.

However, the Directive does allow for an exception to that rule:

By way of exception, the maintenance instructions intended for use by specialized personnel mandated by the manufacturer or his authorized representative may be supplied in only one Community language which the specialized personnel understand.

Let’s say, for example, that you have a German engineer who is located very close to the borders of the Netherlands and Belgium. You may wish to send him to service your machinery in each of those countries. The Machinery Directive allows you to only provide German translations of any maintenance instructions which are intended solely for this engineer – he understands German (one of the Community languages) and therefore you don’t have to also give him Dutch translations, just because he’s going to work in Amsterdam.

But any and all documentation which is intended for the end users in Belgium and the Netherlands must be translated into all applicable languages of those countries.

 

Does the document need to say anything special to show that we’re working within the law?

 

As per the Machinery Directive:

The instructions accompanying the machinery must be either ‘Original instructions’ or a ‘Translation of the original instructions’, in which case the translation must be accompanied by the original instructions.

The “original instructions” are the instructions for which the manufacturer accepts liability and are therefore to be supplied with every machine sold. The manufacturer is required to draft these original instructions in an official language of the EU (which may or may not be the native language of the manufacturer). For English-speaking manufacturers, the documentation written in English is therefore acceptable as the “original instructions”.

It is good practice to state “Original instructions” or a similar declaration on the front page of the documentation so that it is clear to any readers. The translators who are translating your documentation into their language would then replace this with “Translation of the original instruction” or a similar declaration, so that any end users know that the original documents were not written in their native language.

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