How to Write a User Manual When Importing Products to the EU: By Tom van de Wiel

Product manuals, or user guides, are not just ‘nice to have’. At least if you are importing and selling in the European Union.

They are absolutely essential to many product categories, as product manuals are mandatory.

I am aware of several cases, when the customs authorities have seized shipments, simply because the product was not bundled with a manual.

So, we decided to ask an expert, Tom van de Wiel, CEO of Manualise.

In this interview, with one of Europe’s leading experts in this area, you will learn the following:

• What kind of products require a manual?
• In which cases is a product manual not required?
• What information must be included in the manual?
• What can happen if I don’t have a manual?

Tom, please tell us a bit about yourself and what you do at Manualise

I am a 36 year old guy feeling 18 years young and trying to be a good father for our two children. I am also the CEO of Manualise.

‘After obtaining a master‘s degree in Industrial Design at Delft University, a fellow student and myself founded Manualise. As our name suggests, we produce manuals. Yes, you could think of these famous A5 booklets for your TV or washing machine.

But we can also produce instruction videos and integrate augmented reality in all kinds of animations. After all, we are located in the Dutch high-tech city of Delft, famous the world over for its technical university.

It is not only because of our contacts at the university that we have this global, digitally oriented outlook.

We think in both universal graphics and multilingual texts, thus striking the right balance for any customer, wherever on the globe. Among our customers are Electrolux, Leitz, Grundig, AEG, Schneider and AKAI.

It is tremendously gratifying to help these customers and new customers making their own customers happy. Let’s face it: a user manual is more often than not the start of a customer journey. We want to contribute to that journey. And I want to play my part in this endeavor.

Is it mandatory to have a manual for every product category?

No. For example, a teddy bear does not need a manual.

After all, the ‘use’ of a teddy bear speaks for itself. But is this the end of the story? It most certainly isn’t! Let’s concentrate ourselves on the European situation. The detailed regulations coming from the European Union are more or less indicative for the rest of the world.

What do these EU Directives say? They tell us that any product exported to the European market should be safe to use and should not impair someone’s health. This brings me back to the teddy bear.

Although a teddy bear does not need a user manual, the manufacturer and the importer have to keep a technical file in which they state that the product is safe to use, including the reasons why.

When do you know if a product is safe to use?

If you have dealt with all possible risks as they are stated in the relevant EU Directive. One of the requirements in any EU Directive is that a user should clearly understand how to use a product and, as a consequence, use it safely.

If it is not immediately obvious how to use the product, a user manual is required.

However, if daily use needs no explanation, then only warnings of possible risks suffice. Take the teddy bear.

If the teddy bear is rather small, it should carry a warning that it is not suitable for babies or toddlers.

Babies should not be able to take a teddy bear in their mouths. The reason is simple: you want to avoid the risk of choking.

For which product categories is it mandatory to include a manual?

It is not as much the category that a product belongs to that makes a manual mandatory. Take, again, the teddy bear.

Or take a flashlight with only an on/off button.

Both do not need a manual, as long as the manufacturer can confidently state that the product is safe to use.

Take another example that is in the same category – toys – as the teddy bear: a small electric car to be used by small children of say 5-8 years old.

Such a car needs recharging. Because it is not directly obvious how this should be done, a user manual should be included – however small.

Can I be more specific than this? Not really. But if you would like to have an indication which products probably need a user manual, you can find the relevant product categories on a specific EU website.

Here, you’ll find all the information on all 25 product categories that the EU distinguishes – among them boilers, lifts, machinery, medical devices and yes… toys.

In general, what kind of information do I need to include in the manual?

In any user manual, different kinds of information should be included, not only instructions for the daily use of a product.

First, the manual should include a very good table of contents, giving a clear overview of all chapters.

It doesn’t matter whether a user manual is a folded card, a booklet or a book containing tens or even hundreds of pages.

A table of contents makes it possible to scan information quickly, which is essential for any manual. Then the question is: which chapters should be in a user manual?

Roughly speaking, the following chapters should be included:

1. Instructions on how to install the product

2. An overview of the relevant parts and part names of the product

3. Safety instructions

4. Instructions on how to use the product

5. instructions how to recharge and/or refill the product and

6. Instructions on how to dispose of the product in an environmentally friendly manner

How do I know which specific information must be included for a certain category?

If you want to know which specific information is needed for a certain category, it is best to visit the EU site I mentioned earlier.

This site is important for three reasons. First, it gives any importer an overview of all necessary steps to get an official CE marking on its product.

This is the marking saying you comply with the relevant EU Directive. Since importers can be held accountable in the same way that an original manufacturer can be held accountable, it is necessary to be aware of all these steps.

Second, the site lists all 25 product categories, thus giving insight into all product specific requirements that have to be met. For example: does an importer need to show which independent body is involved in certifying EU conformity?

Or is such an institute not necessary and can you carry out the certification process on your own?

Third, the requirements in the EU Directives are indicative of the requirements in the rest of the world, meaning: if you succeed in attaching a CE marking to your product, you stand a very good chance to comply with all necessary requirements in any given country.

Maybe this last fact is not that important for an importer. But an importer can convey this message to its manufacturer, thus helping the manufacturer to explore new markets wherever on this globe.

Are these regulations the same in all EU states, or do I need to keep track of different standards in each one?

One could say that an EU Directive is a special kind of ‘breed’. A EU Directive is not identical to a national law in one of the EU member states.

However, EU member states commit themselves to transform any EU Directive into national law.

In practice, this means that any EU Directive has to force of a national law. Does this imply that the national laws of member states refer to the same harmonized standards, that is to say: do the national laws refer to identical product requirements in all EU member states? Yes.

Does this transformation into national law mean that the judicial consequences are the same in every EU member state? No.

When you do not meet the requirements that are enshrined in the national laws of member states, the judicial consequences can differ from one country to the other.

For example, in member state A you could face a fine if your technical file is not up to standard. In member state B the same offense could lead to detention.

Is English language user guides accepted all over the EU, or do I need to make sure that the manual is written in the language of each member state I sell in?

Although many EU Directives do not state explicitly that a user manual should be written in the local language or local languages of any given EU member state, in practice this requirement should indeed be met.

This has to do with the fact that all relevant EU Directives state that a user manual should be as understandable as it can be, not in the least because of safety reasons. This implies the use of local languages.

Take Belgium as an example. In Belgium, you have three official languages, namely Dutch, French and German.

A user manual should be published in all three languages in order to comply with any relevant EU Directive. There are exceptions though.

Take manuals meant for airplane maintenance. Those working in the aviation sector, should all speak and therefore understand English, at least at the level of STE, Simplified Technical English.

In such a particular case, the English language suffices. But it is safe to say that any given user manual should be published in the official language or official languages of the member state in question.

Most of our customers get the manual printed, and packed with the product, in China. Is it accepted to print the manual in Europe, and bundle it together with the product once it arrives?

Yes, it is possible to print a user manual in Europe and bundle it with the product once it is in Europe. However, a word of caution is definitely called for here.

An importer cannot import a product that needs a user manual if he cannot refer to such a manual. In practice, this means that the importer should, upon request and without any delay, be able to present a digital file containing the user manual.

This in turn implies that the user manual should already be there when the product is shipped to an EU member state.

Maybe it is also good to note that strictly speaking it is not mandatory to bundle the product with a printed version of the user manual.

For example, one could also provide a bundle containing only the product and a quick reference card, while referring to the full-blown manual by providing a URL.

If you would do that, there is one catch though: if a customer wants a printed version of the complete manual, the importer is obliged to send it to him by snail mail. People who don’t have a digital device should always be able to get hold of the user manual.

Thank you Tom. What kind of services can Manualise offer importers?

We can offer importers all services that have to do with instructing people how to use a specific product.

Manualise can be a one stop address for any importer: we are specialized in technical writing, but also consider ourselves to be specialists in creating all kinds of visuals, including, of course, videos. Apart from that, we can also tell importers what kind of legal requirements should be met when it comes to technical documentation.

And… what if this technical documentation needs translation? Of course we can find the right translator for the job. Needless to say that we also take care of ‘localization’. Localization means: taking into account regional subtleties.

Take the Anglo-Saxon phrase ‘1,200 words’. In the Netherlands and in continental Europe, we use a dot instead of a comma: ‘1.200 woorden’. Yes, even in Europe, there are differences.

We spot them and make sure everything turns out just fine!

How can they get in touch with you?

If a reader would be interested, we are most willing to listen. He or she can visit us and contact us at www.manualise.com.