Which language do instructions for use and CE documents have to be in?
Everything addressed to operators, maintenance staff and the operating company has to be in a language those people easily understand, determined by the member state in which the machine is made available, in practice its official language. This covers the instructions for use, safety information and warnings, markings on the machine, HMI texts and the EU declaration of conformity. Not subject to the language requirement are the internal technical documents and purely project-related documents between manufacturer and operating company; those may stay in English if both sides work with it.
Which language is decisive?
What is decisive is not the language of the manufacturer, not the corporate language and not the language of the buyer, but that of the member state in which the machine is made available. The Machinery Regulation frames it as a requirement on the outcome: the information has to be easily understood by users, and which language that is, is determined by the member state concerned. In Germany that is German, in France French, in Belgium Dutch, French or German depending on the region.
From this follows the most common error in projects: the fact that the operating company's maintenance staff speak good English changes nothing. The duty attaches to the country, not to the language skills of individual people. Instructions for use in English only, for a machine operated in Germany, are a defect, even if nobody at the plant would ever have missed a German version.
If you deliver to several countries, you need each of those languages. The additional language versions belong in the technical file.
Which document needs which language?
| Document or information | Language | Why |
|---|---|---|
| Instructions for use | Official language of the country of destination | Addressed to operators and maintenance staff at the operating company |
| Safety information and warnings on the machine | Official language of the country of destination | Has to be understood in the moment of danger without looking anything up |
| Labelling of controls and HMI texts | Official language of the country of destination | Part of the information on the machine |
| EU declaration of conformity | Language required by the country of destination | Accompanies the machine and is also addressed to market surveillance |
| Declaration of incorporation and assembly instructions | Language required by the country of destination or agreed with the incorporator | The addressee is the manufacturer of the final machinery |
| Instructions for maintenance by the manufacturer's own specialists | Language of those specialists, English included | Exception: the addressee is not the operating company's staff |
| Risk assessment, calculations, test records | Free, no requirement | Internal technical documents, not user documents |
| Interface descriptions, FAT and SAT records, specifications | Freely agreed, usually English | Project documents between specialists, not operating information |
| Data sheets and declarations of bought-in components | Free, as supplied by the supplier | Part of the technical file |
The market surveillance authority can require a translation of the technical documentation into a language it understands. Free therefore does not mean untouchable for good.
How do I decide for an individual document?
Original instructions and translation
Every language version has to be marked: the version produced by the manufacturer carries the wording original instructions, every translated version the wording translation of the original instructions. This marking is not a formality; it determines which version prevails in case of doubt.
Responsibility for the accuracy of the translation stays with whoever places the machine on the market in the country concerned. Having something translated delegates the work, not the responsibility. In practice this means: safety-related passages have to be proofread technically, not only linguistically. A translation provider without a mechanical engineering background reliably confuses terms such as guard, cover and interlock.
A special case arises when a distributor or importer makes a machine available in a further country and has it translated for that purpose. They then carry responsibility for that version and attach it to their own documentation.
Digital provision changes none of this. Instructions as a PDF behind a QR code are subject to the same language requirement as a printed manual, including the duty to supply the safety information on paper free of charge on request, likewise in the language of the country.
Practical rules for multilingual projects
- Clarify the destination countries in the quotation. The question of where the machine will stand determines the translation effort and belongs in the costing, not in the project phase.
- Fix the language version per document type by contract: instructions for use in German, project documentation in English is a clean and common arrangement.
- Think of HMI texts early. Display texts are regularly forgotten because they sit in the control project rather than with the documentation team.
- Choose language-neutral safety signs and pictograms where possible; they reduce the translation volume and work immediately.
- Put all delivered language versions into the technical file, with revision status and assignment to the serial number.
- For deliveries outside the EU, separate rules apply: Switzerland requires one of its official languages, the United Kingdom English with UKCA marking.
Sources and standards
- Machinery Regulation (EU) 2023/1230: language requirements for instructions for use and the declaration of conformity
- Machinery Regulation (EU) 2023/1230, Annex III: information and warnings on the machine, instructions for use
- Machinery Regulation (EU) 2023/1230, Annex V: EU declaration of conformity
- EN ISO 20607: instruction handbook, general drafting principles
- EN ISO 7010: safety signs, language-neutral marking
Editions of standards and their harmonised status change continuously. Check standard numbers and editions against the current list in the Official Journal of the EU before applying them. This article is a technical classification and does not replace legal advice.
Frequently asked questions
Are English instructions enough if everyone at the plant speaks English?
No. The language requirement attaches to the member state in which the machine is made available, not to the language skills of the people present. For a machine in Germany a German version is required, even if the company's working language is English. Supplying an English version in addition is of course permitted.
May project-specific documents be in English?
Yes. Interface descriptions, FAT and SAT records, specifications, acceptance documents and technical clarifications are addressed to specialists on both sides and are not operating information. If the project language is English, they stay in English; record that in the contract. As soon as such a document contains operating or maintenance instructions for the operating company's staff, the language requirement applies again.
Does the EU declaration of conformity have to be translated?
It has to be available in the language or languages required by the member state in which the machine is placed on the market or made available. A bilingual version on one sheet, source language plus national language, is common.
What applies to the maintenance instructions for our own service technicians?
Instructions addressed solely to specialists commissioned by the manufacturer may be written in a language those specialists understand. That is the exception you can rely on, but only as long as the document is genuinely not intended for the operating company's staff. As soon as the operating company carries out maintenance itself, it is an ordinary maintenance instruction with the full language requirement.
In which language does the technical documentation have to be?
For the internal file there is no fixed requirement. The market surveillance authority can however require a translation into a language it understands. In practice it is sensible to keep at least the load-bearing documents, the risk assessment and the list of standards, in the language of the manufacturer's location.
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This article was produced with AI assistance and reviewed for technical accuracy before publication. Editorial responsibility within the meaning of Art. 50(4) of the AI Act (EU) 2024/1689 lies with Heinrich Knutas.
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