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Can You Publish Your Manual Solely Online (2022 Update)?

03/10/2021 Ferry Vermeulen & Jean-Pierre Barsoumian Law & Legislation

When it comes to product information, this probably has been the most frequently asked question we’ve heard over the last decade or so. Without doubt, this is because companies see that online manuals have many advantages over their printed counterparts. European law has also been evolving constantly and so has - for some products - made it legally possible to place instructions online. As a result, it’s not longer always required to supply a full printed user manual together with the packaged product.

Ever since the rise of digital media, the paper manual has increasingly become a hurdle for many marketers, product developers, and UX designers. That’s why its gradual abolition is a relief for many companies, especially for those which operate in consumer or industrial electronics on an international scale because of the benefits of cost reduction and a better customer experience.

But what about other product groups that fall under CE marking, like machinesmedical devices or toys?

Unfortunately, a clear answer cannot be given. The possibilities depend on a number of factors. But there is hope! Slowly but surely, progress in legislation is being made and we are actually expecting some exciting developments in the near future. Through this article,we want to inform you about the possibilities companies have today, in order to give them a head start towards the developments of tomorrow.

At the end of the article we introduce our PO/D system™, which stands for Print Online Determination System. It includes all of the aspects you need to take into account when choosing the right medium for your instructions.

electronic user manual

Example of an online manual for a hardware product

What are the legal possibilities for creating online manuals?

When it comes to legal matters, simple questions can turn into complex questions in the blink of an eye. In our case this is because the requirements for the publication format (medium) are fragmented within several sources of European legislation. And to make it even more complex, the requirements concerning the medium are not mentioned in the respective directives and regulations.

However, some of the accompanying guidelines to the directives do describe certain applications concerning the medium; some vertical and horizontal standards give specific requirements on the allowed medium; and EU-countries themselves have legal requirements concerning the medium of the manual. You just need to know where to look.

Fortunately, the EU has been working steadily to simplify and modernize legislation. Since the introduction of the New Legislative Framework in 2016, only a few guidelines still require a printed manual (or safety instructions). In fact, in the Blue Guide, which was developed for the implementation of this new product safety legislation, it states that instructions (unless specified otherwise) may also be delivered in a different format with the product, rather than in print. However, printed safety information must still be provided along with the product. But by looking at the pace the digital economy, software and e-commerce are developing, we have to conclude that the Blue Guide will soon become out of date. Fortunately, an update to the Blue Guide is in progress. This is expected by the end of 2021.

The update will contribute to the EU’s efforts towards further harmonization and standardization, address certain aspects of the circular economy, such as the remanufacturing and treatment of used goods, certain legal implications of Brexit, as well as clarifications around the position of “end-users” and “own use” of products. But what’s interesting regarding our question, is that the draft is also expected to make an amendment in relation to the obligation to provide a printed manual. Hopefully, creating more elbow room for manufacturers to determine which safety information is relevant for their users.

So, all in all, in order to determine our legal possibilities, we need to map out the product specific requirements within the available jurisdictional bandwidths, while also identify the possibilities which are on the horizon. This combined approach will eventually form the framework with which a well-motivated management decision can be made to decide what and what not to include in the printed documentation.

online manual

Example of an online manual for a hardware product


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What are the advantages of an online manual?

You’ve probably asked yourself this question before. Indeed, the answers to this question may even be obvious to you. But actually, a thorough inventory of the specific advantages of an online manual will help you make a decision about what and what not to print.

Every manufacturer wants to worry less about legislation and spend more time on things that require immediate attention, like design, sales or operational challenges. But in this case, it’s the end user we don’t want to lose sight of.

End users wish to retrieve information at the time they need it. They do not think in terms of channels or journeys. They simply want to resolve a problem as fast as they can and assume that the information they need is available through the channel of their choosing. For example, when folding a stroller into the car, somebody will be more likely to consult an online manual on a smartphone, than going back inside the house and searching for the manual.

Other advantages of online or electronic manuals:

  • Smartphones support accessibility technologies, like text-to-speech applications, or a zoom-function, making instructions more accessible for people with disabilities.
  • Users can find information much easier by using a digital search function.
  • An electronic manual can also provide instructions through multimedia forms, such as video, which can be extremely effective.
  • The same online document can be referred to by several people at once. When it comes to paper manuals, there is usually just one physical copy available.
  • By making information more visual with the assistance of video and images, the number of returned products is reduced.
  • Electronic manuals are easier to modify and improve, allowing the user to always have access to the latest information.
  • In situations where safety is especially important, it can be logged that electronic documents were received or comprehended.
  • The instructions will always fit the packaging. This is important for products in growing markets, where the manuals keep expanding because of the growing number of translations they contain.
  • There would be a dramatic decline of printing and transportation costs for the manufacturer.
  • They make a concrete contribution to manufacturer sustainability goals.
  • An electronic manual embodies a company’s ambitions. It shows that a company embraces the changing times, with user-friendliness and consideration for the environment as central themes.
  • Greater possibilities of marketing integration.
  • The retrieved information can be captured using analysis tools. This provides valuable input for the optimization of a product.
  • All of these advantages contribute to a better competitive position.

There are many tools available with amazing features to create digital instructions, like MadCap Flare, ViziApps, Paligo or Swipeguide.

online manual legal requirements

Example of an online manual for a hardware product

What are the possibilities for publishing your manual online?

It is clear that the advantages of electronical manuals are significant and groundbreaking, both for users and manufacturers. But it’s still a demanding job to map out the actual possibilities and pitfalls, because they are product, market and company dependent. Simply put: every product has its own unique approach. For this reason, we’ve developed a system to assist our clients through the decision-making process on what content could be included online and what needs to be provided in a print-based format.

The framework we use for this type of assessment is called the P/OD system. It’s a thorough, step-by-step approach that offers the right tools for a responsible and low-risk decision.

The P/OD system is made up of the following steps:

  1. Determine “Big Savers”
  2. Identification requirements, directives and regulations
  3. Identification requirements guides
  4. Identification requirements standards
  5. Identification national requirements
  6. Identification requirements test institutes
  7. Determination of requirements on content
  8. Vision and decision
  9. Pitfalls checklist
  10. The technical file

We regularly organise free webinars. During our webinars we will talk you through these steps and explain how to research these requirements yourself.

So, if you would like to know more about:

  • how European product safety legislation can easily be found and applied;
  • how to determine what information can legally be published online and what not;
  • creating user instructions that comply and avoid legal pitfalls;
  • saving money on printing costs;

The next one will be held on October 28th 2021

Sign up for our free webinar now. 

The webinars are hosted by Ferry Vermeulen, owner and managing director of INSTRKTIV. Ferry has become a well know technical communicator over the past 15 years, hosting a popular podcast, YouTube channel and blog with over 23k visitors a month. With his companies, Ferry helped enterprises like VW, Electrolux, AEG, GE, Schneider Electric and Akzo Nobel create award winning manuals. Ferry is a member of the tekom European Advisory Board for Legislation & Standards.


A step-by-step approach to develop CE-compliant user instructions and avoid legal pitfalls.