The UK’s decision to leave the EU poses questions for regulators and industry alike. One question many businesses will an answer to is how leaving Europe will impact the Conformité Européenne (CE) Marking Directive, which applies to EU machinery and electrical and medical products. Currently, under the CE Marking Directive, all importing countries must translate labels, instructions for use, packaging and user manuals into the designated language of the user for all products which could potentially cause harm if not used properly. Typically, sections of documentation and materials related to safety must also be translated.
But with the Brexit decision, will CE Markings still be required in the UK at all, and what will be the implications for their translation? Let’s take a look.
Does Brexit change everything?
The first important point to note is that, at the moment, nothing changes. For the next 24 months, the UK will remain a full member of the EU and it will be expected to meet every single one of the existing single market measures in full.
Even after our exit, the directives on which the CE Markings are based are the single market measures the exit campaigners wish to preserve. So, while we might have relinquished any control over how these measures are applied in the future, UK companies will still have to abide by the regulations if they want to sell to the single market.
What about CE Marked products manufactured and sold in the UK?
As a manufacturer of CE Marked products that are only sold within the UK, you may think the CE Markings will no longer apply following our exit from the EU. However, as the system has been accepted in the UK and throughout Europe for 20 years or more, the UK is likely to continue using CE Markings to maintain product safety and free trade.
What are the current CE Marking translation requirements?
CE Marking is required for 22 product categories which have specific directives. The directives state that importing countries must ensure labels, instructions for use, packaging and safety information must be translated into the language of the country the product/equipment is to be sold in. Generally, it is the manufacturer who will be responsible for the CE Marking translation, although a private labeller which presents itself as the producer can take on this responsibility.
Regardless of the party that translates the documentation, liability remains with the original producer who affixes the CE Marking. In some cases, the manufacturer will write into agreements that the distributor or agent is responsible for CE Marking translations, but that does not transfer the liability.
Failure to comply with CE Marking can lead to an investigation from a regulatory body. If the CE Marking is not translated into a specific language, the regulatory body is likely to want to know why.
The importance of using a professional CE Marking translation team
Any liability that comes from a mistranslation will remain with the manufacturer. Some companies may choose to save money by asking in-country employees or distributors to perform the translation on their behalf, but this approach can be costly, particularly where distributors lack the industry-specific knowledge and language expertise to do the job accurately. While in-country employees may be familiar with the technical specifications of the product, they are not trained translators and may not be aware of the specific CE Marking requirements that apply.
Your CE Marking translation team
At Linguistica International, we use professional mother-tongue translators with specific experience in your industry to deliver a CE Marking translation you can rely on. Call 02392 987 765 or email firstname.lastname@example.org to find out more.