Riferimento del commento
Inviato da
Claudia KLUMPP
Tipo di utente
Business association
European Association for Technical Communication - tekom Europe e.V.
Dimensioni dell'organizzazione
Micro (1 to 9 employees)
Numero di iscrizione nel registro per la trasparenza
Paese di origine

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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