The discussion in the cycle industry has gathered momentum with the new Regulation on machinery. Zedler-Institut has examined original texts from the Regulation on machinery, the applicable standard, the position of the German association for technical communication (Gesellschaft für Technische Kommunikation (Tekom) Deutschland e.V.) and the practical realisation.
Regulation on machinery stipulates paper
The Regulation on machinery states clearly in chapter II, Obligations of economic operators, article 10 (7) and (8) that operating instructions may be provided in digital form. However, for non-professional users or in reasonably foreseeable circumstances where such machines may be used, the manufacturer must provide the safety information in paper form.
The EPAC standard stipulates paper
The EPAC standard DIN EN 15194:2018-11, on the other hand, continues to stipulate the paper form, whereas the tekom supports the digitalisation by emphasizing however that it cannot serve as substitute for the paper documentation of consumer products.
Digitalisation not always accepted
Lawyer Jens-Uwe Heuer-James of the German association for technical communication (tekom) gives his comment on the new option of digital operating instructions in their trade journal “Technische Kommunikation”. He points out that digitalisation is not accepted by everyone, with consumers’ associations in particular expressing concerns. In the B2B sector, there were clear requirements for digital operating instructions, focussing on easy access and comprehensibility.
B2B purely digital yes, B2C purely digital no
In summary, according to Zedler-Institut, the following simple lesson can be derived from the applicable regulations and standards: B2B purely digital yes, B2C purely digital no. When selling components to the bicycle manufacturer, the component manufacturer may supply digital component instructions. However, the bicycle manufacturer and dealer must provide the standard-compliant operating instructions in paper form when selling to the end consumer.
Furthermore, they are one hundred percent without initial suspicion for a trade or market surveillance authority if they will supply printed instructions for the bicycle or the e-bike in the respective national language.
Other countries accept mixed concepts
Hybrid concepts with printed concise instructions and references to extensive detailed instructions via weblink or QR code have successfully established and are accepted by market supervisors and accident prevention authorities in many countries of the European Union as well as in Great Britain and Switzerland.
Author: Tillman Lambert