Hi Victor Thank you for your reply regarding the European languages Q/A session. Yes, my terminology of "base language" was an abbreviation / assumption for: official language of the member State where the conformity assessment procedure is carried out or in a language accepted by the notified body involved.
The other references to languages are called from the references to the marking and labeling directive (incorporated in the TTE/SES Directive) initially numbered 93/68/EEC. This refers to the CE marking but also refers (again not using the exact words) to other marking and labeling requirements called up by the assessment standards. The standards invoke requirements for safety statements and user instructions etc. Most standards call for documentation to be in the language of the country in which the equipment is being marketed (this is clearly stated in EN 60 950 for example). Whilst I would agree that you should get the job done and translate all docs to the language of the market in which you are selling, I have had experience of companies who take the "What is the minimum we have to do approach". I simply gave the minimum requirement (and stated this was the case). O.K. Apologies for rushing this answer out to TREG, I did make some assumptions on interpretation, thanks Victor for pointing these discrepancies. Regards: Bill Ellingford ---------- From: Victor L. Boersma[SMTP:[email protected]] Sent: 07 January 1999 14:43 To: TREG Subject: RE: Language and telecom regulations <<File: C:PROGRAM FILESCOMPUSERVEDOWNLOADUNTITLED.BIN>> Bill Ellingford wrote: Re questions on European languages, whilst regulations regarding conformity to type are harmonised, and the language used for the conformity assessment is accepted as evidence of correct documentation, there is an over riding directive linked to trade within the community (unfortunately I do not have the number) which requires articles placed on sale in individual member states to have sufficient operating instructuctions available with the product in the native language. You do not have to translate everything, some people will produce a country specific user guide but have service and maintenance docs in a base language under the understanding that these are for company persons only. This does mean there is a need for translation of a basic user guide for each primary language. Hope you find this information useful, you may be able to varify the directive from the EC (Group DG III or DG XIII). Bill Ellingford, Approvals Manager, Motion Media Technology Ltd. Bill, I've searched the Directives and have not found any reference to documents needing to be in a "base language". The requirement is that the documentation be in an official language of the member State where the conformity assessment procedure is carried out, or in a language accepted by the notified body involved. I must admit that I do not know what that means if my conformity assessment module does not require involvement of any Notified Body. Seems to me that if NOKIA would want to keep all its documents in Finnish and works with a Finnish Notified Body, there is nothing to stop them from doing that. (No offense meant to Finns, but it is not a common and well understood base language). However, the NOKIA people are astute business people and will want to make sure that their customers, their repairhouses, their conformity assessment bodies and their regulators know what to do with these products. Therefore, if there were enough Swahili speaking interests, they would have the documentation available in Swahili. It only makes sense that any document that the general public needs to read, must be in a language that the general public in any given country can read, without having a masters degree in exotic languages (such as English). Even if it were not in any technical regulation, that is still a marketing requirement. So forget about what the regulations say, and get on with the job of marketing your products. That will require translation into whatever language(s) your market prescribes. As an aside, I can find documentation on the harmonisation of Conformity Assessment Modules but not on the harmonisation of Conformity to Type, apart from module C being a prerequisite or all the other modules. Is that what you meant ? Regards, Vic
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