The European Union has 24 official languages and if your company sells machinery to any of the member countries within the Union or the EEA, the EU Machinery Directive 2006/42/EC stipulates that all instructions and warnings must be available in the official language of that member country, as well as in the original language. What does this mean for you and how can this be handled efficiently and competently?
The machinery sector – producing success
A report from the European Commission published in April 2021 laid bare the importance of the machine manufacturing sector in Europe:
“The machinery sector is a major contributor to the European economy, with a current annual turnover of €700 bn. Machinery and equipment manufacturing was the principal business activity of 80,000 enterprises across the EU27 in 2018. These enterprises had a total of 3 million employees in the EU27 in 2018, according to Eurostat figures.”
Perhaps unsurprisingly, Germany’s sector is the largest in Europe, with a nominal turnover of €226 bn in 2018. However, the Nordic machinery market is making great strides; we saw 5.7% year-on-year growth from 2016 through to 2019, slightly higher than the 5.2% recorded by Germany in the same period, according to a McKinsey report detailing the rise of Nordic companies in the global machinery market.
Relevant content in the local language helps forge stronger bonds with your in-country staff and the networks they are trying to build in a new market. Furthermore, making the effort to localise content for your overseas supply chain shows commitment and goes a long way towards facilitating smoother relationships with those suppliers.
See below how you could categorise the content you are considering for translation. Start by mapping out your stakeholders and content types, then proceed to prioritise them in terms of how much value localising them could add to your new business development goals.
Imports increasingly important
As the European machinery sector has shown resilience and is bouncing back strongly from the upheaval of the two pandemic years, the longer-term trend shows that Europe’s share of the total global market has shrunk from 41% in 1998 to 24% in 2019, while the Asia-Pacific region has increased its share from 28% to 53% over the same period.
As a result, there are significantly more machines and machine equipment coming into European countries from outside the continent; from traditional import markets, such as the USA, and increasingly from Asian countries such as China.
With relatively low import tariffs on machinery, many consider the EU an attractive export target. There is, however, a key hurdle that businesses must be able to clear, preferably with as little friction as possible, and that is compliance with all relevant EU directives and regulations.
For machine importers in the EU, the big one is Directive 42, a.k.a Directive 2006/42/EC of the European Parliament and of the Council of 17 May 2006 on Machinery, and Amending Directive 95/16/EC.
Purpose of Directive 42
The purpose of this directive is to create a common standard for safety across all member states of the EU and EEA, both for users and the general public. Although member states are responsible for such standards within their own respective territories, the directive is aimed at reducing barriers to cross-border trade within the Union by diverging standards. Any equipment that fulfils the requirements of the directive may be sold legally within all member states of the European Union and EEA.
The machine regulation regulates…
…machinery, interchangeable equipment, safety components, lifting accessories, chains, ropes and webbing, removable mechanical transmission devices, and partly completed machinery, among other machinery.
The directive gives a detailed definition of the term “machine”, and all machines that fit this definition and are not specifically excluded, are covered by the regulation. A conveyor belt, for example, is considered a machine in its own right because it fulfils the criteria of being a mechanical moving part that is an interchangeable piece of equipment. But the entire machinery that the conveyor belt is part of, for example newspaper prints or a bottle filler, is also considered a machine in its assembled state.
For all machines that fall under the directive’s definition, it is necessary to provide appropriate instructions and safety notices, according to the expected level of proficiency of the user – it may be necessary to write very different instructions to a general consumer compared to a professional and trained operator. The instructions must also be localised to the individual country in which the machines are sold, as per section 1.7 of the directive; “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. 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 EU has 24 official languages, so all information and warnings must be available in those 24 languages if the machinery is to be sold throughout the Union. If you are only selling to one or three countries, for example, only that one or those three languages need to be included.
In most cases, instructions and warnings for any product, including machines, are written in the language of the manufacturer, so if a machine is produced in Germany, the original instructions and warnings are likely to be in German. Rather than composing new instructions for the Finnish, Swedish and French markets, for instance, the original German content is translated into these official languages. Even if a company hedges its bets by having its instructions and warnings written in English, so often the Lingua Franca of our day, this will not be enough to fulfil the requirement of the directive.
Who is responsible for implementation?
The responsibility for ensuring that the instructions and safety warnings are compliant with Directive 42 depends on two circumstances: The default position is that the manufacturer, which means any individual or company who designs and/or manufactures completed or partly completed machinery, as defined above, is responsible for the conformity of this machinery. However, in the absence of a manufacturer as defined above, any individual or company who “… places on the market or puts into service machinery or partly completed machinery covered by this Directive shall be considered a manufacturer.”
This may include those cases where importers who aren’t themselves the manufacturer, but may sell equipment, including equipment that has been assembled from various imported parts, will for the purpose of this regulation be regarded as the manufacturer.
How to ensure translations are compliant
An obvious challenge for any company or person who is the responsible party, is not only to have the relevant texts translated into all required EU languages – potentially all 24 – but also to ensure that these translations fulfil the formal quality requirements.
Instructions and maintenance documentation often consist of complicated technical jargon that an average multi-language speaker might not be familiar with. It’s crucial here to use the correct terminology, because a mistake could have profoundly negative consequences, and even lead to accidents or personal/property damage.
Partner with machine experts
To make the process of ticking the boxes and fulfilling the language requirements of Directive 42 easy for you, we at Sandberg offer you a partnership with the experts. Over the past two decades, we have built up a strong base of internal competency and skills in the field of technical translation, with our linguists tackling everything from rock crushing and timber felling machines to hoisting, garage gates and garden maintenance equipment. You can read more about technical translation generally, and how 22% of manufacturing companies reported lost business due to language barriers, in this blog article.