Instructions, CE marking and languages: what the regulations actually require
Selling a machine in Spain without Spanish instructions is not a commercial misstep: it is a regulatory breach, enforceable in the event of an accident. Here is the map of linguistic obligations, market by market.
Published on 16/09/2026 · 7 min read · Manuce, document translation by specialists
In France: the Toubon law
Law No 94-665 of 4 August 1994 requires French for the designation, offer, presentation, instructions for use, description of the extent and conditions of guarantee of any good or service marketed in France, as well as for invoices and receipts.
In practice: an imported product sold in France must carry information in French, even if the buyer is a professional who speaks perfect English. A translation may accompany it; it cannot replace it.
The Labour Code adds an internal dimension: an employment contract executed in France is drawn up in French, and any document imposing obligations on the employee or necessary for the performance of their work must be in French. A safety instruction displayed in a workshop only in English is unenforceable.
In the European Union: the language of the country of placing on the market
The principle is consistent from one text to another: instructions and safety information must be provided in the official language or languages determined by the Member State in which the product is placed on the market. Each sectoral regulation sets this out in its own way.
- Regulation (EU) 2023/988 on general product safety, applicable since December 2024, requires this for consumer products, in a language easily understood by consumers.
- Machinery Directive 2006/42/EC, replaced by Regulation (EU) 2023/1230 applicable from January 2027, distinguishes between the original instructions and their translation, which must bear the statement "translation of the original instructions".
- Medical devices, toys and personal protective equipment each have their own specific requirement.
The EU declaration of conformity follows the same logic: it must be translated into the language or languages required by the destination Member State. Always check the text applicable to your product before deciding what needs to be translated: sectoral rules take precedence over the general principle.
What must be translated in a technical file
In order of regulatory priority:
- Safety instructions and warnings — this is what will be raised against you first;
- Instructions for use and maintenance, including captioned pictograms;
- The EU declaration of conformity ;
- Labelling and markings on the product;
- Guarantee conditions and after-sales service.
The manufacturer's technical file itself generally remains in the manufacturer's language, unless requested by a supervisory authority.
The three mistakes that cost a recall
Translate the instructions but not the product labels. Text engraved, screen-printed or stuck on the machine forms part of the mandatory information.
Forgetting units and formats. A pressure in bars, a torque in newton-metres, a date in American format: conversion is part of technical translation, and a unit error on a tightening torque has physical consequences.
Letting terminology drift. The same part named three different ways in the manual means a technician ordering the wrong reference. That's what you need to check when proofreading, whatever the tool: note the key terms and search for them in the translation.
What we're asked on this subject
Is an instruction manual in English sufficient for a French professional customer?
No. The Loi Toubon makes no distinction based on the buyer's status: goods sold in France must be accompanied by information in French. Certain exceptions exist for purely internal documents or those intended for non-residents, but they are narrow.
How many languages to sell throughout the Union?
The Union has twenty-four official languages, and a product sold in all member states must be documented in those of the countries where it is actually placed on the market. In practice, manufacturers start with actual markets and add a language when a market opens.
Who is responsible, the manufacturer or the importer?
The manufacturer produces the original instructions; the importer and distributor must ensure they are provided in the correct language, and bear liability if they place a non-compliant product on the market.
Is the statement "translation of the original instructions" mandatory?
In the machinery sector, yes: the original instructions are those produced by the manufacturer, and any translated version must indicate this. It is a one-line statement whose absence is noted during inspection.
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