Is documentation in digital form allowed?


On 21 April, the European Commission published a proposal for a Regulation on machinery products. Annex III includes a provision for instruction manuals in digital form.

This proposal for a Regulation is the result of a revision of the Machinery Directive from 2006, which requires manufacturers to provide the necessary machinery information, such as instructions. The Machinery Directive assumes that providing a printed version is the most viable option to ensure that every user has access to the instructions. However, this requirement increases financial and environmental costs and the administrative burden due to extensive documentation in paper form.

Given that the use of the internet and digital technologies has increased since the Machinery Directive was published, one of the objectives of the revision has been to simplify the requirements for documentation by allowing digital formats, reducing the costs and administrative burden. It must be taken into account, however, that some users are less digitally savvy and that there is a lack of internet access in certain environments.


Provision on Digital Documentation

The Annex III provision on digital documentation reads as follows:

The instructions may be provided in a digital format. However, upon the purchaser’s request at the time of the purchase of the machinery product, the instructions shall be provided in paper format free of charge.

When the instructions are provided in digital format, the manufacturer shall:

(a) mark on the machinery product and in an accompanying paper how to access the digital instructions;

(b) clearly describe which version of the instructions corresponds to the machinery product model;

(c) be presented in a format that makes it possible for the end user to download the instructions and save them on an electronic device so that he or she can access them at all times, in particular during a breakdown of the machine. This requirement also applies to a machinery product where the instruction manual is embedded in the software of the machinery product.


Better Access and Higher Sustainability

One of the pillars of the EU Digital Single Market is ensuring “better access for consumers and businesses to digital goods and services across Europe”. This should also apply to product information. In some industries, especially the software industry, the provision of information in electronic form is already common.

Given the increasing use of smartphones, tablets, etc., instructions in digital form might actually improve access and availability, for example, if the user has lost the paper version. This also makes it easier to keep the documentation up-to-date and improve its distribution since people could easily download the latest version from the internet. After all, the digital transformation is causing changes in users’ research behaviours, and providing information in digital form is certainly more sustainable than using paper versions.

The fact that this proposal takes the form of a Regulation instead of a Directive means that there would be a uniform implementation across the EU. One of the aspects that could potentially be controversial is the fact that the user would have to actively request the printed version of the instructions. However, this is only a proposal, which still has to be discussed and has a long way to go through the European Parliament.


Image source: Gerd Altmann | Pixabay