Products sold in the European Union must often be labelled and come with documentation written in the language or languages required by the EU member states where these are sold. This can be challenging, as it forces companies selling in the EU to translate everything from warning texts to user instructions into multiple languages to stay compliant.
In this guide, we take a closer look at language requirements for products sold in the European Union – with a particular focus on the General Product Safety Regulation.
Content Overview
FREE CONSULTATION CALL (US, EU & UK)
- Request a free 30-minute call with Ivan Malloci to learn how we can help you with:
- Find product requirements
- Certification and labeling
- Lab testing
Which products are subject to EU language requirements?
Essentially all consumer products are subject to the language requirements in the General Product Safety Regulation. As such, you must ensure that your product labels, instructions, and documentation are provided in the relevant European languages – regardless of whether you sell clothing, personal protective equipment, toys, electronics, or even medical devices.
However, there are other regulations and directives that also have provisions relating to Member State languages.
Examples
- Toy Safety Directive
- Low Voltage Directive
- EMC Directive
- Battery Regulation
- Personal Protective Equipment Regulation
- Medical Devices Regulation
User instructions
User manuals and user instruction booklets must be translated in the EU member states where the product is sold. It is common to see manuals printed in the languages of all 27 member states.
This is an example that I found in the General Product Safety Regulation:
Article 9
7. Manufacturers shall ensure that their product is accompanied by clear instructions and safety information in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market. That requirement shall not apply where the product can be used safely and as intended by the manufacturer without such instructions and safety information.
Warning labels and safety information
Some products require specific warning labels or other safety information mandated by regulations, directives, or standards. In other cases, the nature of the product and its associated risks require the manufacturer to create their own warning labels and safety information.
In any case, it is normally required that such warning labels and safety information – both on the product and the packaging – are written in the languages of the EU member states where the product is sold.
In practice, this can result in certain product types essentially being covered in warning label texts in various European languages. This is particularly common when it comes to toys, or other risk products like inflatable swimming aids for children.
This is an example that I found in the General Product Safety Regulation:
Article 19
(d) any warning or safety information to be affixed to the product or to the packaging or included in an accompanying document in accordance with this Regulation or the applicable Union harmonisation legislation in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market.
Product and packaging labels
Information about the product, manufacturer, and contact details must be included on product and packaging labels for certain products. These must also be be understandable by consumers in the Member States where the product it sold.
This is an example that can be found in the Battery Regulation:
Article 38
7. Manufacturers shall indicate on the battery their name, registered trade name or registered trade mark, their postal address, indicating a single contact point, and, if available, web and email address. Where that is not possible, the required information shall be provided on the packaging or in a document accompanying the battery. The contact details shall be indicated in a language or languages which can be easily understood by end-users and market surveillance authorities, as determined by the Member State in which the battery is to be placed on the market or put into service, and shall be clear, understandable and legible.
Declaration of Conformity
The Declaration of Conformity must generally be made available in the required language of the Member State where this product is sold. Some regulations explicitly state this, while others only refer to the DoC indirectly by stating that such requirements apply to documentation in general.
This is an example that can be found in the Battery Regulation:
Article 18
2. The EU declaration of conformity shall have the model structure set out in Annex IX, shall contain the elements specified in the relevant modules set out in Annex VIII, and shall be kept up to date. It shall be translated into the language or languages required by the Member State in which the battery is placed or made available on the market or put into service. It shall be drawn up in electronic format and, where requested, it shall be provided in paper format.
You can normally find the Declaration of Conformity outlines the languages of all 27 Member States on the EUR Lex website.
FAQ
Is it sufficient to only use English when selling in the EU?
The General Product Safety Regulation is clear in that you must provide user instructions, label information, and documentation in the official language of the EU member state where you are selling. As such, English would only be sufficient for the two EU member states with English as an official language – namely Ireland and Malta.
How do I know which languages to include?
Most of our customers include the languages of the countries they actively sell to in the European Union. For example, a Swedish company selling on Amazon in the EU would likely ensure that their labelling and documentation is at a minimum made available in the following languages:
- Swedish (as this where they are located)
- English
- German
- French
- Italian
- Spanish
- Polish
In the example above, I assume that they will make their products available on the Amazon marketplaces in the European Union.
Does this mean that we need to include the language of all 27 member states?
In theory, you could receive an order from a consumer in any EU member state even if you are not actively marketing your products there. The General Product Safety Regulation only mentions that warning labels and documents must be provided in the required language of the Member State in which the product is made available on the market.
However, in practice, there can be differences in how Member States enforce this. They may not be able or interested in taking action when it comes to a small number of parcels – but a retail store establishing themselves in a country would certainly need to comply.
Does this apply to e-commerce companies?
Yes, Article 19 of the General Product Safety Regulation specifically states that the language requirements apply to distance sales – which also include products sold online.
Does this apply to Amazon sellers?
Amazon’s policy requires that sellers ensure compliance with the regulations in the markets where they sell. In other words, their requirements concerning the languages of labels, instructions, and documentation only reflects those set by the European Union.
Keep in mind that this also applies to the language of the product listings.
Who is responsible for ensuring that the information is in the correct language?
If you are defined as the manufacturer, then you are responsible for ensuring that all labels and documents are correct and made available in all relevant European languages.
Keep in mind that companies that have products manufactured according to their specification or with their brand name are defined as manufacturers – even if another company makes their products on their behalf.
For example, if you contact a supplier on Alibaba.com to make a product based on your design or with your brand, then that makes you the manufacturer.
Importers are not absolved of responsibility either. The General Product Safety Regulation states the following:
Article 11
4. Importers shall ensure that the product they imported is accompanied by clear instructions and safety information in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market, except where the product can be used safely and as intended by the manufacturer without such instructions and safety information.
In practice, however, it is unlikely that any manufacturer is able or willing to provide translation services.
What can happen if our products do not include the correct languages?
National market surveillance authorities could take action which may result in fines or a sales ban.
