Are user instructions legally mandatory, or just good practice?

Mandatory, but mostly as an obligation of economic operators rather than an essential requirement. Under the LVD (Article 6(7)), the RED (Article 10(8)) and the EMC Directive (Article 7(7)), the manufacturer must ensure the product is accompanied by instructions and safety information, and importers and distributors must check it. Machinery is the case where instructions are also an essential health and safety requirement (Annex I section 1.7.4 of Directive 2006/42/EC, Annex III section 1.7.4 of Regulation (EU) 2023/1230). A product shipped without them is non-compliant even if the hardware is faultless.

In which languages must instructions be supplied?

In "a language which can be easily understood by consumers and other end-users, as determined by the Member State concerned" (LVD Article 6(7), RED Article 10(8), EMC Article 7(7)). The EU text does not list languages; each Member State sets its rule. In France, Article 2 of Law No 94-665 of 4 August 1994 makes French mandatory in the instructions for use of goods. The Blue Guide adds that each economic operator making the product available in a Member State must ensure the required languages are there.

Can I supply the instructions only in digital form?

Not the safety information, unless a specific act says otherwise. The Blue Guide (footnote 114) says safety information must be on paper, while the rest of the instructions may be electronic or on a website if they stay accessible and a paper copy is free on request. Regulation (EU) 2023/1230 allows digital instructions for machinery from 20 January 2027, with paper free of charge within one month on request and paper safety information for non-professional users. GPSR Article 21 allows digital information only in addition to the physical one.

What is the difference between instructions and safety information?

The texts name both without defining them separately. The Blue Guide describes the content as all the information needed for safe use: assembly, installation, operation, storage, maintenance and disposal, including restrictions of use and protective equipment. It also notes that not every act requires both, since not every act is safety related. In practice, the safety information is the part that the Blue Guide says must stay on paper.

Which information must appear physically on the product itself?

A type, batch or serial number or other identification element, and the manufacturer name, registered trade name or trade mark with a postal address indicating a single contact point (LVD Article 6(5) and (6), RED Article 10(6) and (7)). Imported products also carry the importer name and address (LVD Article 8(3)). Where this is not possible, the Blue Guide sets the packaging first, then an accompanying document. The GPSR adds an electronic address, and Regulation 2023/1230 a website, e-mail or other digital contact.

Are warning symbols regulated, or can I design my own?

EU product law does not impose a symbol set for warnings, but the Blue Guide notes that symbols under international standards may replace written statements. ISO 7010 registers safety signs such as W012 (electricity) and M002 (refer to instruction manual), IEC 60417 registers symbols for equipment such as 5019 (protective earth) and 5172 (Class II), and ISO 3864-2 defines the signal words DANGER, WARNING and CAUTION. The WEEE crossed-out wheeled bin is mandatory and set in Annex IX of Directive 2012/19/EU.

Do the instructions belong in the technical file?

For radio equipment and machinery, the texts say so. RED Annex V point (a)(iii) lists "user information and installation instructions"; Directive 2006/42/EC Annex VII part A requires "a copy of the instructions for the machinery"; Regulation 2023/1230 Annex IV part A point (i) requires a copy of the instructions for use. None of these texts requires every language version to be filed.

Who is responsible if the importer adds a translation?

Each operator has its own duty. The importer must ensure the product is accompanied by instructions and safety information in the required language (LVD Article 8(4), RED Article 12(4)) and the distributor must verify it before making the product available (LVD Article 9(2), RED Article 13(2)). Under Directive 2006/42/EC, a translation made by the person bringing machinery into a language area must bear the words "Translation of the original instructions" (Annex I section 1.7.4.1(b)).

User instructions, safety information & languages

Hugues Orgitelloupdated 7 Oct 202613 min read

A product can pass every laboratory test and still be non-compliant because of what ships in the box. The LVD, the RED and the EMC Directive each require the manufacturer to accompany the product with instructions and safety information "in a language which can be easily understood by consumers and other end-users, as determined by the Member State concerned", and each makes the importer and the distributor check it. This guide reads those articles side by side with the GPSR, the Machinery Directive and the Machinery Regulation that applies from 20 January 2027: who must do what, which language, when a digital manual is allowed, what goes on the product itself, and the common readings the texts contradict.

What the texts actually require

The duty comes from the reference provisions of Decision 768/2008/EC (Article R2(7) for manufacturers, R4(4) for importers, R5(2) for distributors), copied into each sector act. The Blue Guide, section 3.1, lists it among the manufacturer obligations, next to the technical documentation and the declaration of conformity. In the LVD, the RED and the EMC Directive it is an obligation of economic operators, not an essential requirement in Annex I. Machinery is different: there, instructions are also an essential health and safety requirement.

Act	Manufacturer	Importer	Distributor	What is added
Directive 2014/35/EU (LVD)	Art. 6(7)	Art. 8(4)	Art. 9(2)	Annex I point 1(a): essential characteristics for safe use marked on the equipment or, if not possible, on an accompanying document
Directive 2014/53/EU (RED)	Art. 10(8)	Art. 12(4)	Art. 13(2)	Accessories and components, including software; frequency bands and maximum RF power for transmitters; restrictions per Member State (Art. 10(10))
Directive 2014/30/EU (EMC)	Art. 7(7)	Art. 8(4)	Art. 9(2)	Art. 18: specific precautions for assembly, installation, maintenance or use; restriction of use in residential areas, where appropriate also on the packaging
Regulation 2023/988 (GPSR)	Art. 9(7)	Art. 11(4)	Art. 12(1)	Not required where the product can be used safely and as intended without them; online offers list warnings and safety information (Art. 19(d))
Directive 2006/42/EC (Machinery)	Annex I 1.7.4	n/a	n/a	"Original instructions" and "Translation of the original instructions"; minimum contents in 1.7.4.2
Regulation (EU) 2023/1230 (Machinery, from 20 January 2027)	Art. 10(7) and Annex III 1.7.4	Art. 13	Art. 15	Digital instructions allowed on conditions; paper safety information for non-professional users

The LVD, RED and EMC texts also require that "such instructions and safety information, as well as any labelling, shall be clear, understandable and intelligible". The GPSR asks for "clear instructions and safety information".

The language rule: the Member State decides

All the acts in the table use the same formula: a language easily understood by consumers and other end-users, "as determined by the Member State concerned". The EU text sets no list of languages. The answer for a given market sits in national law, and it can be narrower or wider than "the official language".

France. Article 2 of Law No 94-665 of 4 August 1994 makes the French language mandatory in the instructions for use of a good or product. English-only instructions do not meet it.
Switzerland (outside the EU, CE accepted). For low-voltage equipment, Article 11 of the OMBT requires instructions and safety information in at least the official language or languages of the place where the equipment is made available. See Switzerland and the EU-CH MRA for the medical-device rule (MedDO Article 16) and the general rule of LETC Article 4a.
Every other market. Check the national transposition of the act concerned before shipping. Where a Member State has several official languages, read its rule rather than assuming one language or all of them.

The Blue Guide (footnote 113) puts the duty on each economic operator: "It is for each economic operator which makes available the product in a Member State, to ensure that all the required languages are available." A distributor that ships a product into a new country therefore cannot rely on the language set chosen for the first market. Distributors must know "what are the language requirements for labelling, user instructions or other accompanying documents" (Blue Guide, section 3.4).

Document	Language rule	Source
Instructions and safety information	Easily understood by consumers and other end-users, as determined by the Member State	LVD 6(7), RED 10(8), EMC 7(7)
Manufacturer and importer contact details	Easily understood by end-users and market surveillance authorities	LVD 6(6) and 8(3), RED 10(7) and 12(3)
EU declaration of conformity	Translated into the language or languages required by the Member State	LVD 15(2), RED 18(2), EMC 15(2)
Simplified EU declaration of conformity (radio)	Same, and the full text at the internet address in a required language	RED 18(2)
Documentation for an authority on request	Easily understood by that authority, which may accept another language	LVD 6(9), RED 10(12); Blue Guide 3.1
"Manufactured by", "Imported by", "Represented by"	No need to translate these English terms	Blue Guide 4.2.2
RED restriction notice on packaging	Pictogram, or "Restrictions or Requirements in" in a language as determined by the Member State, followed by country codes	Implementing Regulation (EU) 2017/1354, Article 2

Machinery: from "official language" to "easily understood"

Directive 2006/42/EC is stricter on form. Instructions must be in "the official Community language or languages of the Member State" of placing on the market or putting into service (Annex I section 1.7.4). The versions verified by the manufacturer carry the words "Original instructions"; a translation carries "Translation of the original instructions" and must be accompanied by the original (1.7.4.1(a) and (b)). Maintenance instructions for specialised personnel mandated by the manufacturer may be in a single Community language they understand.

Regulation (EU) 2023/1230 drops the "Original instructions" mechanism and aligns machinery with the other acts: the instructions, the safety information and the Annex III information "shall be in a language which can be easily understood by users, as determined by the Member State concerned" (Article 10(7)). See Machinery Directive 2006/42/EC and Regulation 2023/1230.

What the instructions must contain

Outside machinery, the acts describe the result rather than a table of contents. The Blue Guide (section 3.1) says the instructions "should include all the necessary information for the safe use of the product, to enable the consumer to assemble, install, operate, store, maintain, and dispose of the product". It adds that assembly or installation instructions include the inventory of parts and the special skills or tools needed, that operating instructions include restrictions of use, personal protective equipment, maintenance, cleaning and repair, and that a tool intended for professionals may also be used by non-professionals, which the instructions must take into account. "It is for the manufacturer to determine the relevant information."

Content	Where the text requires it
Information to use the equipment in accordance with its intended use	RED 10(8); EMC 18(3)
Accessories and components, including software, that allow the radio equipment to operate as intended	RED 10(8)
Frequency bands and maximum radio-frequency power transmitted	RED 10(8)(a) and (b)
Geographic restrictions on putting into service, completing the packaging information	RED 10(10)
Specific EMC precautions for assembly, installation, maintenance or use	EMC 18(1)
Restriction of use in residential areas	EMC 18(2)
Reasonably foreseeable misuse, wording adapted to non-professional operators	Directive 2006/42/EC Annex I 1.7.4.1(c) and (d); Regulation 2023/1230 Annex III 1.7.4.1
Meaning of the crossed-out wheeled bin, separate collection, return systems	WEEE Directive 2012/19/EU, Article 14(2); Member States may require it in the instructions (14(5))

When identical products are bundled and sold together for one application, the Blue Guide (footnote 111) accepts one set of instructions per shipping unit. Whoever later splits the bundle and sells units individually must add a set to each unit.

Warnings: use the standard signal words

ISO 3864-2 (second edition, 15 December 2016) sets design principles for product safety labels. It defines three signal words, each tied to a colour of the hazard severity panel:

Signal word	ISO 3864-2 definition	Panel colour
DANGER	Imminently hazardous situation which, if not avoided, will result in death or serious injury	Red, high level of risk
WARNING	Potentially hazardous situation which, if not avoided, could result in death or serious injury	Orange, medium level of risk
CAUTION	Potentially hazardous situation which, if not avoided, could result in minor or moderate injury	Yellow, low level of risk

The signal word is optional; when used, it appears in upper case and bold, to the right of the general warning sign. Annex B of the standard gives translations of the signal words, which saves inventing them for each language edition. Each warning should then state the hazard, the consequence and how to avoid it.

Digital versus paper instructions

The default rule is not in the directives but in the Blue Guide (footnote 114): "Unless otherwise specified in specific legislation, whilst the safety information needs to be provided on paper, it is not required that all the set of instructions is also provided on paper but they can also be on electronic or other data storage format or even a website." The full set must then remain accessible for a reasonable period after placing on the market, and "a paper version should always be available free of charge for the consumers who request it".

Regime	Digital instructions	Conditions
LVD, RED, EMC (Blue Guide reading)	Allowed for the instructions, not for the safety information	Reasonable accessibility period; paper free on request for consumers
GPSR, Article 21	Only in addition to the physical information	Electronic means clearly visible on the product, packaging or accompanying document, in the required language
Directive 2006/42/EC	Not provided for	Instructions accompany the machinery
Regulation 2023/1230, Article 10(7), from 20 January 2027	Allowed for all machinery	Access method marked on the machine, packaging or accompanying document; printable, downloadable and savable; online for the expected lifetime and at least 10 years; paper free of charge within one month if requested at purchase; paper safety information for non-professional users
MDR eIFU, Implementing Regulation (EU) 2021/2226 as amended by 2025/1234	Allowed for devices for professional users	See e-label versus physical label
Omnibus IV proposal COM(2025) 503	Would allow electronic instructions under the RED, with safety information still on paper for consumer products	Not adopted on 7 October 2026

For the regulatory label on a screen, a separate question, see e-label versus physical label.

Safety symbols and pictograms

The Blue Guide (footnote 110) notes that "the use of symbols according to international standards may be an alternative to written statements". Three standards cover most needs:

ISO 7010 registers safety signs by family: prohibition, warning, mandatory action, safe condition and fire equipment. Examples: W012 (warning, electricity) and M002 (refer to instruction manual or booklet).
IEC 60417 registers graphical symbols for use on equipment, such as 5019 (protective earth) and 5172 (Class II equipment).
ISO 3864-2 (above) for the layout of product safety labels with signal words.

The crossed-out wheeled bin is not optional: Article 14(4) of Directive 2012/19/EU requires producers to mark electrical and electronic equipment with the Annex IX symbol, preferably according to EN 50419, or exceptionally on the packaging, the instructions for use or the warranty when size or function requires it. See WEEE.

The shape and colour grammar

Family	Shape	Colour	Message
Prohibition	Circle with diagonal bar	Red on white	Do not do this
Warning	Triangle	Black on yellow	Hazard
Mandatory action	Circle	White on blue	You must do this
Safe condition	Square or rectangle	White on green	Escape routes, first aid

A product-specific pictogram that no standard covers should stay inside this grammar, so that the shape and colour tell the user how to read it before the picture does.

Traceability: what must be on the product

The CE marking is not the only marking. The LVD (Article 6(5) and (6)) and the RED (Article 10(6) and (7)) require:

A type, batch or serial number or other element allowing identification of the product.
The manufacturer name, registered trade name or registered trade mark and postal address. The address "shall indicate a single point at which the manufacturer can be contacted".
The importer name, registered trade name or registered trade mark and postal address for imported products (LVD Article 8(3), RED Article 12(3)), without hiding the manufacturer information (Blue Guide 4.2.2.2).

The Blue Guide (section 4.2.2.1) sets the order when the product cannot carry them: "as a first alternative the information should be on the packaging, as a second alternative on an accompanying document such as the instructions for use". Aesthetic reasons do not justify moving it. The single contact point does not need to be where the manufacturer is established and does not need to be in every Member State. "A website address may be given in addition to, but not instead of a postal address."

Data element	LVD and RED	GPSR (from 13 December 2024)	Regulation 2023/1230 (from 20 January 2027)
Identification	Type, batch or serial number	Same, "easily visible and legible for consumers" (9(5))	Type, batch or serial number
Manufacturer contact	Postal address, single contact point	Postal and electronic address, plus single contact point where different (9(6))	Postal address and website, e-mail or other digital contact (10(6))
Importer contact	Postal address	Postal and electronic address (11(3))	Postal address and website, e-mail or other digital contact

For products sold from outside the EU, see authorised representative and importer obligations.

The technical file and the CE marking

The instructions appear in the technical documentation where the text says so: RED Annex V point (a)(iii), "user information and installation instructions"; Directive 2006/42/EC Annex VII part A, "a copy of the instructions for the machinery"; Regulation 2023/1230 Annex IV part A point (i), "a copy of the instructions for use". None of these requires every language version to be filed. Keep the version that ships, so that the file matches what a market surveillance authority will open.

On the product surface, the CE marking sits next to the traceability data and the symbols; see CE marking dimensions and visual rules and multi-marking layouts. The Declaration of Conformity follows its own language rule (table above) and, for radio equipment, a copy or a simplified version accompanies each item (RED Article 10(9)). See EU declaration of conformity.

Dated changes

Date	Change	Source
21 July 2017	Format for the RED Article 10(10) restriction notice published	Implementing Regulation (EU) 2017/1354
13 December 2024	GPSR applies: electronic address, distance-sales information, Article 21 digital information	Regulation 2023/988, Article 52
26 June 2025	eIFU extended to all MDR devices for professional users (publication)	Implementing Regulation (EU) 2025/1234
20 January 2027	Machinery Regulation applies: digital instructions, "easily understood" language rule, digital contact	Regulation 2023/1230
Pending	Omnibus IV would allow electronic instructions under the RED	COM(2025) 503

Claims the texts contradict

Claim	What the text says
"Instructions are an essential requirement under every NLF directive"	Under the LVD, RED and EMC they are an obligation of economic operators (LVD 6(7), RED 10(8), EMC 7(7)); they are an essential requirement for machinery (Annex I 1.7.4)
"The manual must be in all official languages of the target country"	The language is the one "easily understood ... as determined by the Member State concerned"; the national rule decides
"Safety information on paper is only needed for consumer products"	The Blue Guide (footnote 114) sets paper safety information as the default unless specific legislation says otherwise, with no consumer or professional distinction; Regulation 2023/1230 is such specific legislation for machinery
"Several directives already allow digital-only instructions for professional products"	Among the acts above, only Regulation 2023/1230 (from 20 January 2027) and the MDR eIFU rules provide for it; the RED change is a proposal
"The GPSR allows a QR code instead of the printed information"	Article 21 allows digital information "additionally", without prejudice to Article 9(5) to (7)
"IEC 60417 contains the 'read the manual' book sign"	The safety sign "refer to instruction manual" is ISO 7010 M002
"Signal words are Danger, Warning, Caution and Notice"	ISO 3864-2:2016 defines DANGER, WARNING and CAUTION
"The importer only inherits the manufacturer type and serial data"	The importer must add its own name and postal address and ensure the instructions are in the required language (LVD 8(3) and (4), RED 12(3) and (4))
"The technical file must contain the final manual in every language"	RED Annex V and the machinery texts require the instructions or a copy of them, with no language-by-language requirement

Checklist

Instructions and safety information accompany every unit, or every shipping unit for bundles sold together.
Language rule checked for each target Member State; French in France (Law 94-665, Article 2).
RED: accessories and software, frequency bands and maximum power, restriction notice per Implementing Regulation 2017/1354.
EMC: Article 18 precautions and any residential restriction.
Safety information on paper unless a specific act allows otherwise.
Type or serial number, manufacturer name and single postal contact point, importer details where relevant; electronic address for GPSR products.
WEEE symbol on the product.
Declaration of conformity translated as each Member State requires.

For the wider conformity route, see the CE pillar.

Frequently asked questions

Are user instructions legally mandatory, or just good practice?: Mandatory, but mostly as an obligation of economic operators rather than an essential requirement. Under the LVD (Article 6(7)), the RED (Article 10(8)) and the EMC Directive (Article 7(7)), the manufacturer must ensure the product is accompanied by instructions and safety information, and importers and distributors must check it. Machinery is the case where instructions are also an essential health and safety requirement (Annex I section 1.7.4 of Directive 2006/42/EC, Annex III section 1.7.4 of Regulation (EU) 2023/1230). A product shipped without them is non-compliant even if the hardware is faultless.
In which languages must instructions be supplied?: In "a language which can be easily understood by consumers and other end-users, as determined by the Member State concerned" (LVD Article 6(7), RED Article 10(8), EMC Article 7(7)). The EU text does not list languages; each Member State sets its rule. In France, Article 2 of Law No 94-665 of 4 August 1994 makes French mandatory in the instructions for use of goods. The Blue Guide adds that each economic operator making the product available in a Member State must ensure the required languages are there.
Can I supply the instructions only in digital form?: Not the safety information, unless a specific act says otherwise. The Blue Guide (footnote 114) says safety information must be on paper, while the rest of the instructions may be electronic or on a website if they stay accessible and a paper copy is free on request. Regulation (EU) 2023/1230 allows digital instructions for machinery from 20 January 2027, with paper free of charge within one month on request and paper safety information for non-professional users. GPSR Article 21 allows digital information only in addition to the physical one.
What is the difference between instructions and safety information?: The texts name both without defining them separately. The Blue Guide describes the content as all the information needed for safe use: assembly, installation, operation, storage, maintenance and disposal, including restrictions of use and protective equipment. It also notes that not every act requires both, since not every act is safety related. In practice, the safety information is the part that the Blue Guide says must stay on paper.
Which information must appear physically on the product itself?: A type, batch or serial number or other identification element, and the manufacturer name, registered trade name or trade mark with a postal address indicating a single contact point (LVD Article 6(5) and (6), RED Article 10(6) and (7)). Imported products also carry the importer name and address (LVD Article 8(3)). Where this is not possible, the Blue Guide sets the packaging first, then an accompanying document. The GPSR adds an electronic address, and Regulation 2023/1230 a website, e-mail or other digital contact.
Are warning symbols regulated, or can I design my own?: EU product law does not impose a symbol set for warnings, but the Blue Guide notes that symbols under international standards may replace written statements. ISO 7010 registers safety signs such as W012 (electricity) and M002 (refer to instruction manual), IEC 60417 registers symbols for equipment such as 5019 (protective earth) and 5172 (Class II), and ISO 3864-2 defines the signal words DANGER, WARNING and CAUTION. The WEEE crossed-out wheeled bin is mandatory and set in Annex IX of Directive 2012/19/EU.
Do the instructions belong in the technical file?: For radio equipment and machinery, the texts say so. RED Annex V point (a)(iii) lists "user information and installation instructions"; Directive 2006/42/EC Annex VII part A requires "a copy of the instructions for the machinery"; Regulation 2023/1230 Annex IV part A point (i) requires a copy of the instructions for use. None of these texts requires every language version to be filed.
Who is responsible if the importer adds a translation?: Each operator has its own duty. The importer must ensure the product is accompanied by instructions and safety information in the required language (LVD Article 8(4), RED Article 12(4)) and the distributor must verify it before making the product available (LVD Article 9(2), RED Article 13(2)). Under Directive 2006/42/EC, a translation made by the person bringing machinery into a language area must bear the words "Translation of the original instructions" (Annex I section 1.7.4.1(b)).