--- title: "Can we provide the instructions online only?" description: "Under the GPSR and the low voltage and radio directives, the product must be accompanied by instructions and safety information in the language the Member State requires; the texts provide no online-only route. The Commission's Blue Guide expects safety information on paper. The Machinery Regulation (EU) 2023/1230 allows digital instructions on strict conditions from 20 January 2027. Use online versions as an addition." type: "problem" url: "https://www.conphora.com/solutions/problem/instructions-online-only/" markdown: "https://www.conphora.com/solutions/problem/instructions-online-only.md" locale: "en" language: "en" updated: "2026-10-04" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529" tags: ["GPSR", "LVD", "RED", "documentation"] license: "Free to quote with attribution and a link to the page" --- # Can we provide the instructions online only? Under the GPSR and the low voltage and radio directives, the product must be accompanied by instructions and safety information in the language the Member State requires; the texts provide no online-only route. The Commission's Blue Guide expects safety information on paper. The Machinery Regulation (EU) 2023/1230 allows digital instructions on strict conditions from 20 January 2027. Use online versions as an addition. ## Why this happens The question is whether the instructions must physically accompany the product. Under the General Product Safety Regulation (EU) 2023/988, manufacturers "shall ensure that their product is accompanied by clear instructions and safety information" in a language easily understood by consumers, as determined by the Member State where it is made available; the requirement does not apply where the product can be used safely and as intended without them (Article 9(7)). Importers ensure the same (Article 11(4)). Distributors verify it before making the product available (Article 12(1)). Under Article 2(1), third subparagraph, point (b), these articles do not apply to products subject to Union harmonisation legislation, which follow their own act. [1] The CE directives use the same verb. Under the Low Voltage Directive 2014/35/EU the manufacturer ensures the equipment "is accompanied by instructions and safety information" in a language easily understood by consumers and other end-users, as determined by the Member State concerned (Article 6(7)), and the importer ensures it too (Article 8(4)). [2] The Radio Equipment Directive 2014/53/EU requires the same and lists what the instructions contain, such as the frequency bands and maximum radio-frequency power (Article 10(8)). It does allow one document to move online: each item may ship with a simplified declaration of conformity that gives the exact internet address of the full declaration (Article 10(9)). [3] None of these texts provides an online-only alternative for the instructions themselves. The Commission's Blue Guide, which is guidance and not law, reads the acts as requiring the safety information on paper, while the rest of the instructions may be electronic or on a website, kept accessible for a reasonable period, with a paper version free of charge on request (footnote 114). [6] In May 2025 the Commission proposed to allow digital instructions under the low voltage, EMC, radio and other directives (COM(2025) 503) and under several regulations, including the Machinery Regulation (COM(2025) 504). [7] They were proposals, not law, in the texts read. The Machinery Regulation (EU) 2023/1230 is the act read here that does. It applies from 20 January 2027 (Article 54). Its Article 10(7) says the instructions "may be provided in a digital format". The manufacturer must then mark on the product, or where that is not possible on its packaging or an accompanying document, how to access them, present them so that users can print, download and save them, and keep them accessible online during the expected lifetime and for at least 10 years after placing on the market. On the user's request at the time of purchase, paper instructions are provided free of charge within one month. For machinery that non-professional users may use, the safety information essential for putting into service and safe use is provided on paper. [4] The declaration of conformity may also be given by internet address or machine-readable code (Article 10(8)). [4] Online sales add a separate duty. Under GPSR Article 19(d), which sits outside Chapter III Section 1, an online offer must clearly and visibly show the warnings and safety information that go on the product, its packaging or accompanying documents under the GPSR or the applicable Union harmonisation legislation, in a language consumers easily understand. [1] If instructions or warnings are missing, authorities can require the product to be brought into compliance or, where the risk arises only in certain conditions or for certain end users, warnings to be affixed in the language of the Member State, and ensure withdrawal or a prohibition when the operator does not act (Regulation (EU) 2019/1020 Article 16(3)(a) and (e), (4) and (5)). [5] ## How to solve it 1. **Find the instruction rule in each act that applies** Read the manufacturer's obligations of every act the product falls under. Note whether the act says the product must be accompanied by instructions, and whether it provides a digital format and on what conditions. 2. **Separate safety information from the rest** Split the manual into the safety information and warnings a user needs before and during use, and everything else, such as feature guides and troubleshooting. The acts require both to accompany the product; the Commission's Blue Guide accepts the non-safety part in electronic form. 3. **Keep what must ship with the product on paper** Where the act requires the product to be accompanied by instructions and safety information, ship the safety information on paper in the box, in the languages of the country of sale. The Blue Guide accepts the rest online if it stays accessible and a paper copy is free on request. 4. **For machinery from 20 January 2027, meet every digital condition** Mark on the machine or packaging how to reach the instructions, make them printable, downloadable and savable, keep them online for the expected lifetime and at least 10 years, send paper free within one month if the buyer asks at purchase, and keep paper safety information for non-professional users. 5. **Show the warnings in the online offer as well** When you sell online, the offer must show the warnings and safety information that go on the product or in the accompanying documents, in a language consumers in that country understand. That duty is separate from the manual. ## What you need to show - **The printed instructions and safety information per language** — The manufacturer (GPSR Article 9(7); Directive 2014/35/EU Article 6(7); Directive 2014/53/EU Article 10(8)) - **For machinery: the digital instructions, the access marking and the paper-on-request routine** — The manufacturer (Regulation (EU) 2023/1230 Article 10(7)) - **The warnings and safety information shown in each online offer** — The online seller (GPSR Article 19(d)) ## If you do nothing - **The product is not accompanied by its instructions** — Manufacturers ensure the product is accompanied by clear instructions and safety information in a language consumers easily understand, as determined by the Member State, unless it can be used safely without them (GPSR Article 9(7)). - **Importers must check it too** — Importers ensure the product they imported is accompanied by clear instructions and safety information in the required language (GPSR Article 11(4); Directive 2014/35/EU Article 8(4)). - **Authorities can require warnings to be added** — Corrective action may include affixing clear warnings in the language determined by the Member State, and authorities ensure withdrawal or a prohibition where the operator does not act (Regulation (EU) 2019/1020 Article 16(3)(e) and (5)). ## Questions ### Is a QR code on the box enough under the GPSR? The GPSR requires the product to be accompanied by clear instructions and safety information, unless it can be used safely and as intended without them (Article 9(7)). It does not provide an online-only alternative, so a QR code is best used in addition. ### Can the radio declaration of conformity be online? Yes, in simplified form. Each item ships with the full declaration or a simplified one giving the exact internet address of the full text (Directive 2014/53/EU Article 10(9)). The instructions and safety information still accompany the equipment (Article 10(8)). ### When can machinery manuals go digital? The Machinery Regulation (EU) 2023/1230 applies from 20 January 2027 (Article 54). From then, instructions may be digital on the conditions in Article 10(7), including paper on request at purchase and paper safety information for non-professional users. ### Do we have to print the manual in every language? The instructions and safety information must be in a language easily understood by consumers and other end-users, as determined by the Member State where the product is made available (GPSR Article 9(7); Directive 2014/35/EU Article 6(7)). ## Regulations involved GPSR, LVD, RED ## Sources 1. [Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529) — EUR-Lex, 2026-10-04 2. [Directive 2014/35/EU on electrical equipment designed for use within certain voltage limits (consolidated text of 30 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530) — EUR-Lex, 2026-10-04 3. [Directive 2014/53/EU on radio equipment (consolidated text of 30 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0053-20260530) — EUR-Lex, 2026-10-04 4. [Regulation (EU) 2023/1230 on machinery (consolidated text of 27 July 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1230-20260727) — EUR-Lex, 2026-10-04 5. [Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812) — EUR-Lex, 2026-10-04 6. [The 'Blue Guide' on the implementation of EU product rules 2022 (Commission Notice 2022/C 247/01)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)) — EUR-Lex, 2026-10-04 7. [Proposal for a Directive amending Directives 2000/14/EC, 2011/65/EU, 2014/35/EU, 2014/53/EU and others as regards digitalisation and common specifications (COM(2025) 503)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025PC0503) — EUR-Lex, 2026-10-04