Do We Translate? How Manufacturers Cut Costs and Comply With EU Law

The European Union continually crafts legislation to implement its policy of multilingualism. One example is the Machinery Directive, a 63-page document that gives manufacturers targeting the EU market an overview of the government’s language requirements. It is limited to products that are placed on the EU market for the first time―hardly a limit given the scope of what machinery comprises.

The Machinery Directive Application Guide, which runs a hefty 408 pages and explains exactly what a manufacturer operating in the EU market must and must not translate, says products with parts or components not linked together in an assembly are not considered machinery.

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So does the Directive apply to CKD (completely knocked-down) or SKD (semi knocked-down) products? According to the Guide, the law’s definition “does not preclude the supply of machinery with certain parts disassembled for storage or transport purposes,” but machinery manufacturers must provide adequate assembly instructions taking into account the level of education and acumen of non-professional users.

If it has no moving parts, it is not machinery

What about replacement parts? Per the Guide, this does not apply to a single, unlinked replacement part; in short, if it has no moving parts, it is not machinery.

The Application Guide is endorsed by the EC Machinery Committee, but contains this caveat: “Only the Machinery Directive and the texts implementing its provisions into national law are legally binding.”

Regular updates to the Guide will be published here to answer questions agreed upon by the Machinery Committee and Machinery Working Group. The EC invites the public to provide these questions.

Meanwhile, whether manufacturers have issues with the Directive or not, they must translate the following to comply with the law:

  • Information on indicators or displays (any written or verbal info are subject to language requirements)
  • Warnings (symbols or pictograms prefered, but any written or verbal info and warnings should be in the official language or languages of the Member State where the machinery is placed)
  • EC Declaration of Conformity
  • Work instructions (original and translated)
  • Assembly instructions (in an official language acceptable to the manufacturer of the machinery since these are for the manufacturer of the final machinery)
  • Technical documents (available for at least 10 years from manufacture date or, for a series, from the date the last unit was produced)

The Directive also requires any instructions to be labeled “Original instructions” or “Translation of original instructions,” as the case may be. “Original” simply means the instructions are in a language version certified as accurate by the manufacturer and for which he accepts responsibility. If the manufacturer does not provide instructions, then whoever brings the machinery into the language area must provide them.

An exception to the general requirement to translate instructions applies to maintenance instructions for specialized personnel, which may be supplied in only one EU language understood by these personnel. Specialized personnel may refer to a staff or company under contract with the manufacturer.

Sara Gangelhof, Technical Documentation Manager at wind turbine manufacturer Vestas, says they have drawn up internal guidelines detailing what to translate and who pays for it

However, this exception does not apply to maintenance instructions to be carried out by the user or the maintenance personnel of the user, which must still be translated into the official language or languages of the Member State where the machinery is placed.

Speaking to Slator, Sara Gangelhof, Technical Documentation Manager at wind turbine manufacturer Vestas, says since they regularly translate work instructions for the production, transport, installation, and service of their turbines, they have drawn up internal guidelines detailing what to translate and who pays for it.

As such, translated documents have now been integrated into this manufacturer’s production process. Cost savings come from leveraging on their one-vendor policy and using that vendor’s translation memory tools. To ensure quality, the manufacturer still reviews all translations internally.

Translation suppliers can actually support and advise manufacturers in identifying what content requires translation

According to Xplanation, a global language service provider headquartered in Belgium, what some manufacturers may not realize is translations directly link to product liability. They point out some may still regard translation as administrative work that just needs to get done. But when the translation does not work or they have issues with getting them done on time, then time-to-market is jeopardized and costs can escalate.

Translation suppliers can actually support and advise manufacturers in identifying what content requires translation. One client, for whom Xplanation has translated several million words since 2001, usually translates its global technical and marketing documentation into 8–10 languages per product, and has fully outsourced the process to Xplanation.

When manufacturers realize EU Directives are binding pieces of legislation that make translations compulsory, they can turn to their language provider to help find the best solutions.

Xplanation has played a consultant’s role to manufacturers new to navigating the language requirements of the EU. Based on the company’s experience in the manufacturing sector, they are able to advise on deadlines, where to tap expertise, cost-saving measures, and can provide general guidance.

When manufacturers realize EU Directives are binding pieces of legislation that make translations compulsory, they can turn to their language provider to help find the best solutions

Enter the New Legislative Framework

The Machinery Directive is just one EU law that contains language provisions. Another, broader piece of legislation is the New Legislative Framework (NLF). It has mainly to do with product conformity―indicated by the CE marking―which benefits businesses and consumers in the European Economic Area.

The CE marking indicates a product has gone through the process of conformity assessment and has complied with the NLF regulation. But the CE marking is neither proof of compliance, according to the so-called Blue Guide 2016, nor should all products have it. It is actually forbidden to put CE markings on products not required to have them under the New Approach Directives.

Whether or not a manufacturer needs or wants the CE marking, the NLF states the following still need to be translated:

  • EC Declaration of Conformity (this says the manufacturer assumes responsibility for product compliance)
  • Instructions and safety info (required of manufacturers, importers, and distributors)
  • Other documents to show conformity (in a language easily understood by the authority who requests it)

Manufacturers are, however, under no obligation to translate into all required languages the words manufactured by, imported by, or represented by as these words are regarded as easily understandable no matter the language. Also, as long as the characters of the language used allow the reader to identify the country of origin and company name, the address or country name need not necessarily be translated.

The penalties for non-compliance with either the Machinery Directive or any part of the NLF are provided by Member States, who are also tasked with ensuring these laws are implemented.

In the UK, for example, penalties can mean a maximum fine of GBP 5,000 per offense if tried in a Magistrates’ Court or, if in the Crown Court, an unlimited financial penalty. A prison term of not more than two years may also be imposed.

Penalties for non-compliance with the Machinery Directive and the New Legislative Framework are provided by Member States

Saving Cost, Time-to-Market While Maintaining Quality

The hot topic of the moment is the harmonization of various EU legislation. Directives are being aligned by the EC to broader laws, such as the NLF, and new versions of certain directives came into force on April 20, 2016.

Although new directives generally tend to have the same scope and safety objectives as versions immediately preceding, Xplanation says harmonization still impacts a lot of directives in the manufacturing sector.

They say a client, an instrument manufacturer, had to review their entire compliance documentation and be ready with all updated documents before April 20, 2016. This meant increased turnaround times for Xplanation.

To save on cost and time-to-market, Xplanation set up a system to synchronise changes made on source documents during the ongoing translation process. Serving as a satellite for the client’s source document workflow, Xplanation immediately took over translation as soon as the client finished producing the source content.

65% of one client’s content is delivered within one working day; 50% of that content within four hours. This kind of turnaround time has become the norm for many of Xplanation’s customers

Translation memory played an important part of the process, Xplanation told Slator, and it meant substantial savings for the client in that their content was safely reused.

This particular instrument manufacturer had very little time to finish all their documentation in 17 target languages. So Xplanation not only used translation memory technology but also set up a very specific project management system to make the documentation process work and meet the client’s deadline.

For manuals, Xplanation no longer produces new translations each time but reuses previous translations through translation memory technology, which means substantial cost and time savings for clients. For instance, 65% of one client’s content is delivered within one working day; 50% of that content within four hours. This kind of turnaround time and “continuous delivery” model has become the norm for many of Xplanation’s customers.

For another client, the translation cycle for larger 40,000-word manuals was reduced by 30%, from six to only four weeks.

Now that it is a legal requirement to provide all these translations, manufacturers are looking even more to technology to help bring down what are undoubtedly very significant costs, according to the wind turbine company’s Technical Documentation Manager Sara Gangelhof. She says they currently use CMS and XML and continue to work closely with Xplanation to see if any new technology can help optimize the translation process.

Looking way ahead into the future, Gangelhof says, they will digitize instructions more and more. That is, more illustrations, less text; another way to save on translation costs. She concludes they will likely opt for videos someday instead of documents as it does not make sense to read through 20 pages of text before you can start a job when you can, say, watch a five-minute video instead―a development Xplanation agrees is a trend in the business.

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