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Can You Publish Your Manual Solely Online (2018 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.


Do you want to know if your user manual is EU compliant? Do the Quick Scan!


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.



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