Can You Publish Your Manual Solely Online (2018 Update)?

Last week I held a presentation in Tampere, Finland. The topic: can you legally publish your hardware manual online?

It is perhaps the most important change in recent years of European law, when it comes to product information: for many products it is allowed to place their instructions solely online.

It is no longer required to supply the manual in the sales package!

The paper manual was an eyesore to many marketers and information-and-UX designers. According to them, it does not align with the customer journey.

That’s why its obsolescence is a relief for many companies; especially those, within the consumer electronics market, who operate internationally and attach great value to cost reduction and customer experience.

Keep on reading if you want to find out all about this amendment of the law and how it can help your brand or company to directly increase the UX and to save thousands, sometimes even hundreds of thousands of dollars, over the next few months.

What has changed in the product safety legislation regarding creating online manuals?

One of the most frequently asked questions, over the last few years, concerns whether it is possible for companies to place manuals online, instead of delivering a physical copy of it.

That was never quite possible due to the European law’s obligation for companies to deliver a paper manual along with the product.

This obligation was not usually found directly in a European product directive, but could be found in the documents accompanying the directive. This was listed in the guide of the old EMC Guide 2004/108/EC:

The Commission services have taken as a bench-mark that the information provided to the end-user has to allow him/her to use the apparatus without any further steps on their behalf. (…) It is not accepted (in other cases than those vote from the view above) that electronic media or a hyper link is sufficient as an alternative to information in paper copy. The end-user has an absolute right to quick and easy use of the apparatus they have purchased with no further obligations (such as access to the internet) ". Source: EMC Guide – February 2010 (p. 40).

The legislation nowhere explicitly stated that any form other than paper was allowed. In addition to that, the general opinion was that companies should not assume that every user has internet.

With the introduction of the “New Legislative Framework” (NLF), in regards to the marketing of products, and the subsequent replacement of several product directives in 2016, there remain only a few guidelines which state that a paper manual is necessary.

In fact, in the Blue Guide, (last update: July 2016), which was developed for the implementation of this new product safety legislation, states the following:

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. However, a paper version should always be available free of charge for the consumers who request it.

This concludes that:

• Instructions, unless specified otherwise, may also be delivered in a different format with the product, rather than in print.
• Information about the safety/the safe use of the product must still be delivered in paper form (hard copy) along with the product.
• Any company must, at the request of a consumer, make a hard copy of the user manual available to the consumer.

Contact us if you want to know what this change means for your company.