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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