The translation of the Declaration of Conformity is one of the most overlooked aspects of CE marking. Many manufacturers regard it as an administrative formality and leave it until the last minute. However, it is far from a minor detail. This document declares that a machine meets the applicable safety requirements, and everyone who receives it, including the authorities, must be able to understand it. The new Machinery Regulation (EU) 2023/1230, which will apply from 20 January 2027, brings this issue back into focus. Market surveillance will become stricter, and Member States will be required to establish proportionate and dissuasive penalties. A translation error can end up costing far more than the money saved on translation services.
Who Decides Which Language the Declaration of Conformity Must Be Written In?
The language is determined by the Member State in which the machine is placed or made available on the market. Regulation (EU) 2023/1230 requires the EU Declaration of Conformity to be translated into the languages required by that country. The same principle applies to instructions and safety information intended for users.
Manufacturers may draw up the original document in their preferred language. However, they must provide the locally required version for each destination market. If you sell machinery in Italy, Germany and Denmark, you will need at least three language versions, each of which must be fully consistent with the others and with the technical documentation.
What Changes Under the New Machinery Regulation?
Unlike Directive 2006/42/EC, the Machinery Regulation is directly applicable in all Member States and does not require transposition into national law. However, language requirements and penalties remain partly within the remit of individual countries. Some have already published detailed national provisions. Denmark, for example, requires the Declaration of Conformity to be in Danish. Germany has proposed requiring German for both instructions and declarations.
In Italy, established practice requires documentation to be provided in Italian. However, before shipping machinery, it is advisable to check the national provisions in force at the time of sale. The Regulation also permits instructions to be provided in digital format, provided they can be downloaded and printed and remain accessible online for at least ten years. These materials must also comply with the language requirements of the destination country.
Penalties and Reputational Risk
Article 50 of the Machinery Regulation requires Member States to establish rules on penalties and ensure that they are enforced. Although there is not yet a uniform framework, the direction is clear: a declaration drawn up in the wrong language constitutes formal non-compliance. Market surveillance authorities may require corrective action, prevent the product from being sold or order its withdrawal from the market.
The consequences extend beyond financial penalties. Machinery held up at customs, distributors suspending orders or customers challenging the documentation can all damage a company’s reputation. For businesses exporting to multiple countries, a reputation for reliable documentation is a competitive advantage, and an inaccurate translation can put it at risk.
Inaccurate Translations and Manufacturer Liability
Manufacturers are responsible for the conformity of their machinery and the accompanying documentation. If a warning is mistranslated, liability does not transfer to the translator: it remains with the manufacturer who placed the product on the market. Inadequate or misleading instructions may constitute a failure to provide appropriate safety information, potentially resulting in civil liability and, in the most serious cases, criminal consequences.
Consider a practical example: if an instruction to “isolate from the power supply and lock out” is translated simply as “switch off”, an operator could carry out maintenance on machinery that is still energised. In the event of an accident, the instruction manual would be among the first documents examined. An inaccurate translation could therefore become evidence against the manufacturer.
Independent Revision and ISO 17100
The Declaration of Conformity is a technical document with legal and safety implications, and its translation can be managed in accordance with ISO 17100, the international standard for translation services. This standard requires every translation to be revised by a second qualified linguist. In practice, the translator produces the target text, while an independent reviser compares it with the original, checking terminology, completeness and accuracy.
The standard also requires verified professional competences, documented processes and version traceability, enabling manufacturers to demonstrate, in the event of an inspection, how the document was produced and by whom. Aglatech14 is ISO 17100 certified and applies this process to all texts with safety or legal implications, including Declarations of Conformity.
What Can Be Post-edited and What Always Requires a Human Translator?
In technical translation, the term post-editing is frequently used. It refers to the revision, by a professional linguist, of text produced by a machine translation system. This approach is becoming increasingly widespread as a way of reducing turnaround times and costs, but it is not suitable for every type of documentation. Declarations of Conformity and safety-related texts are among the documents for which post-editing alone is not sufficient.
This is because not all technical content carries the same level of risk. Technical data sheets, spare parts catalogues and marketing materials are often repetitive and contain controlled terminology. In these cases, machine translation followed by post-editing can be an efficient solution. It reduces time and costs without compromising quality, provided the post-editor has the necessary subject-matter expertise.
Other documents call for a different approach. Warnings, operating manuals, safety instructions, labels affixed to machinery and Declarations of Conformity should always be handled by specialist human translators, with independent revision. The practical rule is simple: if an error could cause injury or compromise the legal validity of a document, the text should not be entrusted to a fully automated process.
Checklist for Manufacturers
- Map your markets: list the countries where you sell or intend to sell your machinery.
- Check language requirements: verify the national rules applicable in each Member State.
- Create a glossary: establish consistent technical and safety terminology from the outset.
- Choose certified providers: look for compliance with ISO 17100.
- Archive all versions: retain translations alongside the technical documentation.
- Keep documents up to date: every change to the original document requires a new, verified translation.
An Investment That Protects Your Machinery and Your Reputation
The language of the Declaration of Conformity is not a matter of corporate preference. It is determined by the country in which you sell your machinery, and responsibility for the quality of the documentation remains with you. Under the Machinery Regulation, scrutiny and expectations regarding documentation will increase. Entrusting safety-related texts to a certified language services partner is one of the most effective ways to reduce legal risks and protect your company’s reputation.
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