Re: CE documentation (long)

Subject: Re: CE documentation (long)
From: Geoff Lane <geoff -at- GJCTECH -dot- FORCE9 -dot- NET>
Date: Sat, 4 Jul 1998 16:39:48 +0100

-----Original Message-----
From: KAHN, DEBRA <DEBRAK -at- FTC1 -dot- AEI -dot- COM>
>Thank you, Geoff, for your checklists.
Glad to help.

A quick comment is in order. Please understand that the directives require
certain things of *instructions* (not manuals). Instructions instruct the
user how to use the product safely. A manual usually contains (in addition
to instructions) information that can enhance the user's enjoyment of the

> --Under what circumstances do we translate manual material?
Depends upon the applied directives. For example, to comply with the
Machinery Directive, all the instructions must be translated. For other
directives (for example, toys), you don't even need to supply instructions
unless they are essential for safety.

You can, however, supply translated instructions that meet the Directive's
requirements. You can then supply untranslated additional information that
'enhances' the customer's enjoyment of the product. Of course, this
additional information can contain nothing that is essential to the safe use
of the product.

> --How much of the manual needs to be translated?
Again, this depends upon the directive. The Machinery Directive is the
worst -- all must be translated. My local Department of Trade & Industry
rep insisted that (strictly) we should supply two sets of instructions to
English customers (one in the language in which we drew up the instructions,
and a 'translation' to English). However, I think his point was that some
of the legislation's provisions are ludicrous. Other directives (Electrical
Safety?) don't call for translation.

> --Some people interpret the CE language requirement broadly: since the
>language requirement says "a major language," and since English is a major
>language in many European countries, an English-only manual should
>suffice--most of the time.
No -- the requirement is for an *official* major language. English is an
official major language in very few countries.

> --If the CE language requirement is interpreted more narrowly, then aren't
>we free to seek a waiver of translation from the customer?
Yes and no. The legislation states that the product be accompanied by the
translation when it reaches its end user. It does not say *who* is to do
the translation. You are, thus, free to contract out the translation to the
customer. However, you would be well advised to obtain the customer's
undertaking in writing. You should also obtain the customer's agreement
that they will supply a copy of the translation should your declaration of
conformity ever be challenged. In the end, you are responsible for
*arranging* the translation.

> --If the customer insists on translation, aren't we again free to
>with the customer the extent of the translation, the timeline, and the
Of course you are. Your company will engage in a contract to supply the
complete product (including instructions) for an agreed price. However, you
should remember that either party can walk away before the agreement is

> --In the past (mostly for GS-marked products (for Germany)), we have
>translated only the compliance/safety page and general installation and
>operation instructions and placed the translated sections within the
>manual. Would this suffice for any CE-mandated translations?
Depends on the directive(s). Some directives don't explicitly demand
translations, others do.

> --Translations are expensive and take time. In the past we have told our
>sales/marketing people that a translation of a manual can take up to 12
>weeks (usually less) and cost in the neighborhood of $12,000. They balk at
>these numbers. Some think, I guess, that translations ought to be "free"
>(the way technical writing is "free") and happen instantaneously.
And we all know how such hidden expense bumps up production cost. FWIW, my
client produced custom engineering products, that is 'one-offs'. Were my
client to follow the entire letter of the Machinery Directive, the cost to
the end customer would be ten times the pre-CE cost. This would have put my
client out of business. We sought (and found) 'loopholes' that we could
employ to significantly reduce the cost of compliance.

From your concern about translation costs, I guess that you are in the same
boat as my client. Mass-producers can easily absorb such costs because the
cost-per-unit is a few cents. However, if you only produce a few units of
any product then the cost of conformity can make your product uneconomical.
You may want to take a close look at your product range. Are your products
modular? Can you use modular documentation? You could then have the
documentation modules translated and assemble the English and translated
versions to match the delivered product.

>(As I side note, one time one of our sales guys only half jokingly asked me
>if our quick print vendor could just press a button and have an
>manual print in German!!!)
At first, a not unreasonable question. A number of translation bureaux use
translation software. This software tends to be expensive and it certainly
doesn't do everything. However, it does give the human translator a huge
head-start. The technology can't replace the human translator just yet, but
it certainly can help in keeping the cost down.


Geoff Lane
Cornwall, UK
geoff -at- gjctech -dot- force9 -dot- net

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