This is a grey area. At least it was when I checked a few years ago. The LVD directive 73/23/EC(obsolete) and 2006/95/EC do not
explicitly mention translation. Some standards mention that safety instructions are published in one of the official languages, and some require that they be understood in the target country. Some countries require full translations, some require nothing at all. You (your customer) have 2 possibilities: Comply with the demanded translations Start legal action against german authorities Complain at the European Commission Directives text: http://eur-lex.europa.eu/LexUriServ/Lex riServ.do?uri=OJ:L:2006:374:0010:0019:EN:PDF The Guide on LVD does not mention any translations: http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf The GPSD directive (applicable to consumer goods) states: http://eur-lex.europa.eu/LexUriServ/Lex riServ.do?uri=OJ:L:2002:011:0004:0017:EN:PDF ‘safe product’ shall mean any product which, under normal or reasonably foreseeable conditions of use including duration and, where applicable, putting into service, installation and maintenance requirements, does not present any risk or only the minimum risks compatible with the product's use, considered to be acceptable and consistent with a high level of protection for the safety and health of persons, taking into account the following points in particular: (i) the characteristics of the product, including its composition, packaging, instructions for assembly and, where applicable, for installation and maintenance; (ii) the effect on other products, where it is reasonably foreseeable that it will be used with other products; (iii) the presentation of the product, the labelling, any warnings and instructions for its use and disposal and any other indication or information regarding the product; (iv) the categories of consumers at risk when using the product, in particular children and the elderly. The feasibility of obtaining higher levels of safety or the availability of other products presenting a lesser degree of risk shall not constitute grounds for considering a product to be ‘dangerous’; >From this you may conclude that for consumer products translation of instructions may contribute to a safe product. Regards, Ing. Gert Gremmen [email protected] <mailto:[email protected]> www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: [email protected] [mailto:[email protected]] Namens Kim Boll Jensen Verzonden: Friday, November 20, 2009 10:31 AM Aan: EMC PSTC Onderwerp: Language of safety instructions Hi all We have been met with requirements from Germany that all safety information shall be in German, or else the CE marking is invalid. The product is a laser product under the following standards; EN 60825 and EN 61010. None of these standards have any requirements like this. Is there a specific German requirements and what does it include. Are there any other countries with same kind of requirements? Best regards, Mr. Kim Boll Jensen Bolls Rådgivning Ved Gadekæret 11F DK-3660 Stenløse Phone: +45 48 18 35 66 [email protected] www.bolls.dk - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]>
