European Association for Technical Communication - tekom Europe e.V.
tekom Europe
tekom Europe's objectives are to promote and further develop technical communication in Europe, to set European standards for the quality of technical communication and to increase the importance given to technical communication throughout Europe, both in commerce and among the general public.
ID: 194995512904-93
Lobbying Activity
Response to Revision of the Machinery Directive
13 Aug 2021
The European Association for Technical Communication – tekom Europe e.V. welcomes the draft for a new machinery regulation.
Please find attached our feedback.
Read full responseResponse to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products
2 Dec 2020
The feedback of our professional association is attached.
Read full responseResponse to Review of the general product safety directive
1 Sept 2020
According to GPSD Art. 2 lit b) iii), ”the presentation of the product, the labelling, any warnings and instructions for its use and disposal and any other indication or information regarding the product” have to be particularly taken into account when it comes to product safety.
Such information is increasingly provided in digital form using current technologies.
The GPSD does not make any statement regarding the form of the instructions.
We believe that the statement of the “Blue Guide” in footnote 99 is questionable:
“…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.”
The approach of presenting only safety information in paper form disregards essential context: Without context for action, safety-related information can cause, rather than prevent, danger. Consumers may feel compelled to use the products solely based on the safety information.
We believe that the GPSD must clearly state the following:
(1) Instructions including safety information (also called information for use) are an essential and integral part of the product.
(2) The quality of this information affects the safety of the product.
(3) The manufacturer is responsible to ensure the safety of the product including the decision in which form and by which medium the information for use is provided.
This can be done in a targeted revision of the Directive (option 2).
In addition, more guidance could be provided on aspects to be considered by the manufacturer, such as the following:
- Target audience of the product
- Situations in which the consumers need the information (use cases)
- Intended use of the product and reasonably foreseeable misuse
- Effectiveness of provision, so that the information reaches the consumer safely
The goal is that the manufacturer provides the information for use in the most suitable form for the target audience.
Read full responseResponse to Revision of the Machinery Directive
8 Feb 2019
The European Association for Technical Communication – tekom Europe e.V. is a multinational association and a forum for about 9,000 professionals across Europe being active in technical communication and related fields. Amongst these professionals tekom Europe is counting over 2,680 machinery manufactures, suppliers for machinery manufactures and consulting/service companies related to the business of machinery manufacturing. Our members develop all kinds of information for use for products, such as
• instructions for use, assembly, disassembly, maintenance and repair,
• technical construction file,
• product labels or warning messages on the product.
The Fourth Industrial Revolution (Industry 4.0) is of great importance for the machinery industry and has a significant impact on technical communication and instructions. We are of the opinion, that Industry 4.0 is not adequately considered by the Machinery Directive and its guidance documents so far. The backbone of Industry 4.0 is the “digitalized facility” consisting of “intelligent machinery” – consequently one may ask for digitalization in a wide spread of different areas and in the end for information for use in electronic form.
A representative survey among our members and further professionals in 2015 disclosed that 82% of the interviewed persons / companies “feel” that they are not allowed to provide instructions in electronic form due to legal constraints.
Therefore tekom Europe strongly recommends that in the area of Industry 4.0 digital documentation – information for use in electronic form – is allowed explicitly within a revised machinery directive or within more general EU regulation.
The explicit regulation could be accompanied by more detailed explanation with regards to the concrete use cases of user information in an electronic format within the guidance document. The industry as well as the market surveillance authorities surely need guidance in applying the new regulations and in particular in dealing with information for use in an electronic format.
Currently our members experience, that in some countries the market surveillance authorities do strictly apply the technical standards and do not reflect the facts of the individual case. Even worse, some of our members did also report that the market surveillance authorities have not been able to assess the quality of information for use such as instructions which did result in an unpredictable, inappropriate acting of market surveillance authorities. Unpredictable acting of market surveillance authorities is an obstacle for the free movement of goods within the European Union. A revision of the Machinery Directive would help to align acts of market surveillance authorities by precise regulation for the user information in particular regarding the format and a proper guidance document reflecting the different use cases.
Considering the foregoing, tekom Europe is in favor of option 2 in combination with option 4.
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