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Can You Publish Your Manual Solely Online (2019 Update)?

Ferry Vermeulen Law & Legislation

Perhaps it is the most important change, in recent years of European law, when it comes to product information: for many products it is now 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.

This “electronization” is a pretty logical step when you consider that 72% of the people in industrialized countries people from ages 18 up to 80 own a smartphone.

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What are the advantages of an online manual?

This adjustment allows companies to worry less about legislation and to spend more time thinking about the UX, creating a terrific advantage.

They can now deal with more valuable questions, such as: "When does my user want access to information and through which medium?”

For example, users will often have their phone close to them; making phones a substantially easier way of accessing information at any given time, as opposed to the old paper manual.

Here are a number of examples. When folding the Bugaboo into the car, a user will be more likely to consult a manual online, than to go inside and search for the manual.

Also, when work in healthcare, on airplanes, with a machine or at the top of a telephone pole, it would be much easier to have an electronic manual instead of paging through a paper manual.

Fun fact: during a presentation of Fokker Services, Tim Milder noted that the paper manual of an airplane is often heavier than the plane itself.

A user wishes to retrieve information at the time they need it, through one of the channels that are available to them. It is important to realize that a user does not think about this in terms of channels.

They simply want to resolve the problem as fast as they can and will assume that the information they need is available through each channel!

Other advantages of online or electronic manuals:

  • The instructions will always fit in the packaging. Especially for companies within the consumer electronics market, such as Philips, Braun and Sony, the obligation
    presented a huge problem. With the growing markets, the manuals kept expanding because of the growing number of translations they contained. On top of that, the manual also had to fit inside the box or blister pack.
  • Electronic manuals are easier to modify and improve, allowing the user to always have access to the latest information.
  • There are no, or less, printing and transportation costs for the manufacturer.
  • It contributes to shaping a durable image of the company.
  • An electronic manual fits better within the current time frame. It shows that a company embraces the changing times, with user-friendliness as the central focus.
  • An electronic manual can also provide instructions through multimedia forms, such as video.
  • By making information more visual with the assistance of video and images, the number of returned products is reduced. For example, many of Philips’ irons are returned from England, where it is customary to iron your clothes using scented water, which many irons cannot tolerate. By making the explanation visual, this can be prevented. (Source: Sprout).
  • Users can find information much easier by using a digital search function.
  • The same document can be consulted or edited by several people at once. When it comes to paper manuals, there is usually just one physical copy available unless more were made.
  • In situations where safety is urgently important it can be shown/logged that electronic documents were received and/or were comprehended.
  • 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 several tools available with which you can create electronic instructions. Some tools are MadCap Flare, ViziApps, Squidds and Swipeguide.

 

 

IEC/IEEE 82079 and ISO 20607 about Publishing Information Online

The year 2019 will always be remembered as the year that two new standards on ‘instructions for use’ saw the light: ISO20607 and IEC/IEEE 82079.

Since many European Directives, such as the R&TTE, LVD and EMC Directive were repealed in 2016 and replaced by their successors, for many products, it became allowed to place the user instructions solely online. Also, the new standards on instructions for use offer new opportunities. In many cases, it is no longer required to supply the full manual in the packaging. This “electronization” is a pretty logical step when you consider that 85 percent of European households had an internet connection in 2016 and Western Europe and Eastern Europe respectively have a 75 percent and 60 percent smartphone penetration.

In this article, I will discuss how you can legally digitise your product information. I will tell you when you can publish your documentation online and when print is still required. I will discuss the most important parts of the ISO 20607 and IEC 82079 related to online publication.

What does European legislation allow when it comes to online publication?

Before 2016, the obligation to deliver printed instructions with the product was not usually found directly in a European directive itself. It could be found in the documents accompanying the directives, for example in the guide that accompanied the old EMC directive 2004/108/EC. This EMC guide stated:

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 hyperlink 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) ".

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: 27 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.

The IEC/IEEE 82079-1:2019 and online publication

The IEC/IEEE 82079-1:2019 Preparation of information for use is the successor to the IEC 82079-1:2012 Preparation of instructions for use.

This international standard provides principles and general requirements for information for the use of products. According to the standard, information for use is necessary for the safe use of a product, helpful for the efficient and effective use of a product and often necessary to fulfill market, legal, and regulatory obligations.

The standard has been developed by 2 convenors and 23 members from 9 countries. Therefore it has broad international consensus. Compared to its predecessor, it contains some major updates. The 82079 is a so-called horizontal standard: it does not apply to just a specific product or sector, but contains rules across sectors for almost all branches of the industry. The standard gives requirements on the content, structure, quality, process, media and format of information for use. Information for use is considered as an integral part of the supported product.

The content for information for use is comprised of information based on three pillars: instructional information, conceptual information and reference information. The information for use may include various information products that are selected, presented, and delivered in different media to meet the needs of different target audiences. The concept of information for use according to the new standard. 

The following is new in the 82079-1:2019:

  • Change of title. In the new title, “information for use” is used instead of “instructions for use” and the IEEE has been added as the co-veloped the standard with IEC. The standard uses “information for use” instead of “instructions for use”. Instructions for use was used to indicate content that covers more than instructions/activities or operations to be performed.
  • The standard’s requirements are divided into requirements for information for use and requirements for the information management process. It includes a separate clause with requirements for the information management process. This clause does not apply to consumer products.
  • The new standard describes clearly how to claim compliance, with both the requirements for information for use and with the requirements for the information management process.
  • The new standard includes a new clause named “professional competencies,“ which tells us that the creation of information for use shall be assigned to competent persons and even gives clear requirements on the proficiency level.
  • When it comes to usability, there is an integration of the principles of minimalism.
  • Information for use is divided by the 82079 into three information types. This is in order to make safe, efficient, and effective use of a supported product possible, according to the standard. These information types are comprised of conceptual information that the target audience needs to understand, instructional information to be followed or considered, and reference information to be consulted when needed.
  • A new clause on ‘structure of information for use’ is included. It contains a complete new setup compared to the former standard. It emphasizes the use of leading criteria for structuring.
  • A new clause on the “media and format of information for use“ is included. This is also a complete new setup compared to the former standard. It covers the former section ‘presentation of instructions for use’ and more. This clause is of importance for the publication form of the information for use.

The 82079 standard has become less strict when it comes to the media and format of the information for use and should be based on the needs of the target audiences. It is considered important that the media allows easy and permanent access to information for use and that the chosen media are durable. As possible media that can be used, the 82079 names a combination of text, photographs, safety signs, graphical symbols and illustrations, video, animated illustrations, speech, braille, AR, VR, etc. When choosing the medium, it is considered to be important to address the conditions of use when choosing the media and format. For example, in the case of low light, the medium should light up the text and speech should not be used in a noisy environment. Paper should not be used on wet environments or clean rooms. Depending on the needs of the target audience, information for use can be provided inside the packaging, on or within the product; on the packaging (but not only on the packaging), on websites or as separately provided in collateral documentation.

The following are important things to consider when formatting and presenting your online information for use:

❏     Make sure that downloadable information can be displayed on commonly used devices.

❏     Make sure that text fonts, safety signs and graphical symbols are clearly legible and follow the recommended minimum sizes.

❏     Maximise brightness contrast.

The ISO 20607 and online publication of instruction handbooks for machinery

The ISO 20607 for Instruction Handbooks has been developed by ISO, the International Organization for Standardization, where the new 82079 has been developed by IEC/IEEE. There is a relation between 82079-1:2019 and 20607 standards: at the moment that the development of the IS0 20607 started, the committee was not yet aware of the revision of the 82079 standard. When they did become aware of this fact, the scope of 20607 changed.

The current 20607 standard now is based on the 82079 standard and should be seen as an enhancement to 82079 that contains additional guidelines for developing instruction handbooks for machinery specifically. Therefore, any guidelines as described in the 82079 have not been repeated in the 20607, such as the principles of minimalism or requirements on the information management process.

The reason to develop a standard for machinery only, is because there was the need for a standard that provides safety specifications for machinery specifically, that is more detailed than 82079. The 20607 has a strong relation with ISO 12100 standard for risk assessment and risk reduction.

Because the 20607 should be considered as an addition to the 82079, both standards should be applied when creating an instruction handbook for machinery. When you apply both standards (as soon as they are harmonised) for the development of an instruction handbook, you create the highest possible presumption of conformity with the corresponding requirements of harmonisation legislation.

So, focussing on machinery and as an enhancement to the 82079, the 20607 covers the following topics:

  • Content and structure of the instruction handbook;
  • Language and formulation/style guide;
  • Forms of publication.

The 20607 creates much more freedom when it comes to electronic distribution of instruction handbooks, compared with how this was interpreted in the Guide to Application of the Machinery Directive. The Machinery Directive does require that ‘Before placing machinery on the market and/or putting it into service, the manufacturer or his authorised representative shall provide, in particular, the necessary information, such as instructions’. However, it is not mentioned in which format the instructions should be provided and if this must be printed and included with the product, or whether these can be provided online. The Guide to Application of the Machinery Directive states the following: 

Section 1.7.4 does not specify the form of the instructions. It is generally agreed that all health and safety related instructions must be supplied in paper form, since it cannot be assumed that the user has access to the means of reading instructions supplied in electronic form or made available on an Internet site. However, it is often useful for the instructions to be made available in electronic form and on the Internet as well as in paper form, since this enables the user to download the electronic file if he so wishes and to recover the instructions if the paper copy has been lost. This practice also facilitates the updating of the instructions when this is necessary.

Although the Guide is not legally binding, it has always been generally agreed that user instructions should be provided in paper form, at least the health and safety related information.

This might change as soon as the 20607 becomes harmonised. Section 7 of the standard describes that the instruction handbook must be provided as agreed with the customer, taking local legislation of the country where the machinery is placed on the market and/or put into service for the first time. Basically it means that it is required to fulfill the (European and local) legal requirements and if requirements are absent, the contract shall be taken into account. The conract can also be an addition to local legislation. You can interpret this as that a manufacturer has to have an agreement which regulates the provided languages and publication forms. In principle, the handbook can be a paper handbook, placed on an electronic storage medium (such as a cd, usb-stick or on a device accompanying the machinery), published online or have a visual or auditory form.

Conclusion

The paper manual is an eyesore to many marketers and information- and UX designers. According to them, it does not align with the customer journey. That’s why the obsolescence of a paper manual 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.

With the new standards, there is more freedom on the publication for, at least on paper. But how easy is it to legally provide online instructions only? You need to take agreements, local laws and European law into account when you make your decision. In daily reality, determining what the possibilities are, still might lead to confusion and discussion. Things to consider when you are researching what to to:

  • What kind of product do you have (Machinery, electrical equipment, toy, medical device)?
  • What legislation does apply and which standards do I want to apply?
  • Who is my target audience and what are their needs?
  • Where do I sell the product and what tells local regulation about the publication format?

Some say that it is still a lot of work to sort everything out and there is not one easy solution to be applied for all member states. Others say that the new standards offer more freedom. What do you think?

 

DO YOU WANT TO KNOW HOW YOU CAN CREATE A COMPLIANT USER MANUAL FOR THE EU?

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

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