Translation and Language Industry Observations

This post describes the rules mandated by the Spanish government regarding the provision of manuals in the Spanish language when marketing technology products in Spain and its outlying regions.

When marketing products to Spain, they must be accompanied by a technical description specifying the product components and any data that is considered appropriate about its manufacture, maintenance, use and disposal. Furthermore, almost all tech products and systems must be accompanied by a manual or instructions for use so that consumers can become familiar with the correct way of use in order to avoid failures in the expected results or damages derived from misuse. For this reason, manufacturers are taking care to write these documents in order to present the information in an understandable way for a target audience that are usually not experts in the relevant field of technology.

Manufacturers of technical products usually pass a series of suitability assessments in order to market their products in a certain country. As part of this process, explanatory documents are attached in relation to the nature and use of the products. Translation of these same documents is also considered in most regulations. It is often necessary to provide translated versions so that their inclusion in the market is considered suitable.

In Spain, Royal Decree 1644/2008 of October 10 establishes the rules for the marketing and commissioning of machines. In section 1.7 of the decree, a series of provisions related to the information related to the products are set out, including:

  • the need to present the information in an understandable and unambiguous manner
  • the need to provide the products with alerts to warn the consumer in case of danger or malfunction
  • warnings about possible residual risks
  • marking that must appear on each of the machines (the name and full address of the manufacturer, the designation of the machine, the CE marking, model designation, serial number, year of manufacture, etc.).

In addition to this, section 1.7.4 of the decree specifically refers to the instruction manuals, where the following is established:

When marketed and/or put into service in Spain, each machine must be accompanied by an instruction manual in Spanish. This manual will either be an original manual or a translation of the original manual. In the latter case, the translation must be accompanied by the original manual. However, maintenance instructions intended for specialized personnel authorized by the manufacturer or its authorized representative may be provided in only one of the languages of the European Community that the specialized personnel understand.

This paragraph recognizes the need to localize instructions and technical specifications in the language of the recipients and the specialized public. In the case of Spain, it is mandatory to produce a version in Spanish. Manufacturers can also request translations into other languages spoken within the territory (including inter alia Basque, Catalan and Galician). However, at present it is not an essential condition, although the regional authorities can issue provisions to this respect that would be applicable only within their respective territories.

In the same text of the Royal Decree, the lingual requirements for instruction manuals continue to be discussed:

The instruction manual will be written according to the principles listed below.

1.7.4.1 General principles for writing the instruction manual:

  1. The instruction manual shall be written in one or more of the official languages of the European Community. Original manual must be printed on the language version(s) verified by the manufacturer or his authorized representative.
  2. When there is no original manual in Spanish, the manufacturer or its authorized representative, or the person responsible for the introduction of the machine in the linguistic zone in question, must provide a translation at least in Spanish. The translations will include the mention Translation of the original manual.
  3. The content of the instruction manual must not only cover the intended use of the machine, but also take into account its reasonably foreseeable misuse.
  4. In the case of machines intended for non-professional users, the level of general training and insight that can reasonably be expected from said users will be taken into account when writing and presenting the instruction manual.

These guidelines dictate the need to record when a manual is the original version and when it is a translated version. This is an important aspect because, for legal purposes, the original version is the only one that is considered applicable. In this way, the possible damage derived from an error in the translations of said original text is eliminated.

Translation of manuals for the Spanish market should be done professionally, in order to minimize the risk of errors that could delay or prevent the launch of products in Spain. Seek out Spanish translation services that have proven experience in translation of technical manuals to Spanish.

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