--- title: "The supplier's documents are in Chinese only" description: "EU law does not require the technical file in your language. On a reasoned request you must supply it in a language the authority easily understands, and instructions and safety information must be in the language the country of sale sets (GPSR Article 11(4); Regulation (EU) 2019/1020, Article 4(3)(b)). Ask for an English version, check that the content matches your model, and translate the consumer texts yourself." type: "problem" url: "https://www.conphora.com/solutions/problem/supplier-documents-language/" markdown: "https://www.conphora.com/solutions/problem/supplier-documents-language.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", "suppliers-imports"] license: "Free to quote with attribution and a link to the page" --- # The supplier's documents are in Chinese only EU law does not require the technical file in your language. On a reasoned request you must supply it in a language the authority easily understands, and instructions and safety information must be in the language the country of sale sets (GPSR Article 11(4); Regulation (EU) 2019/1020, Article 4(3)(b)). Ask for an English version, check that the content matches your model, and translate the consumer texts yourself. ## Why this happens EU product law sets language rules by reader, not by document type. For what the consumer reads, the General Product Safety Regulation (EU) 2023/988 requires the importer to ensure that the product is accompanied by clear instructions and safety information in a language consumers easily understand, as determined by the Member State in which the product is made available (Article 11(4)). An online offer must show the warnings and safety information in that language too (Article 19(d)). The Low Voltage Directive 2014/35/EU sets the same duty for importers of electrical equipment (Article 8(4)) and requires the EU declaration of conformity to be translated into the language or languages the Member State requires (Article 15(2)). [1] [3] For what the authority reads, the rule is different. The economic operator responsible for a product must, after a reasoned request from a market surveillance authority, provide all information and documentation necessary to demonstrate conformity in a language that authority easily understands (Regulation (EU) 2019/1020, Article 4(3)(b)); the GPSR applies that task to consumer products through Article 16(1). Importers of electrical equipment have the same duty under the Low Voltage Directive (Article 8(9)). The acts read here do not require the technical documentation to be drawn up in a particular language; they set the language of what is provided on request. [1] [2] [3] The Commission's Blue Guide explains how this works in practice. The national authority might accept a language it understands that differs from the national language; the language is subject to negotiation with the authority and could be a third language if the authority accepts it. On a reasoned request it is sufficient for the importer to provide the part of the technical documentation related to the claimed non-conformity, so any request for translation should be limited to those parts. [4] A file nobody can read is still the importer's responsibility. Before placing a product on the market, the importer must ensure that the manufacturer drew up the technical documentation (GPSR Article 11(1)), keep a copy for 10 years (Article 11(6)), and refrain from placing a product it has reason to believe does not conform (Article 11(2)). Checking what a foreign-language report actually says is part of that. [1] ## How to solve it 1. **Sort the documents by who reads them** Three groups, three language rules. Instructions, safety information and warnings are read by consumers and must be in the language the country of sale determines. The EU declaration of conformity is translated into the languages the Member State requires. The technical documentation and test reports are read by authorities, in a language they easily understand, when they ask. 2. **Ask for an English version first** Many laboratories and factories issue reports in English or bilingually on request. The Commission's guidance notes that an authority may accept a language it understands that is not its national language, and that the language is open to discussion with the authority. An English file is often the practical common ground. 3. **Check the content you cannot read** Model numbers, standard numbers and editions, dates, the name of the laboratory and the factory address are readable in any language. Check them against your product and label. Use a translation tool to find the conclusions and any failed or not-applicable clauses, and ask the supplier about every one you find. 4. **Prepare the parts an authority will ask for** On a reasoned request, it is enough to provide the part of the technical documentation that relates to the claimed non-compliance. Keep a translation of the summary parts ready, such as the risk analysis, the list of standards and the test results, rather than translating the whole file. 5. **Produce the consumer texts yourself** As importer you ensure that instructions and safety information accompany the product in the language of each country of sale, and that your online offer repeats the warnings in that language. Write them from the manufacturer's original, check them against the product, and keep each version with a date. ## What you need to show - **Technical documentation and test reports, in English or with translated summaries** — The manufacturer, with a copy kept by you (GPSR Article 11(6); Regulation (EU) 2019/1020, Article 4(3)(b)) - **EU declaration of conformity in the languages of the countries of sale** — The manufacturer (LVD Article 15(2)) - **Instructions, safety information and warnings per language** — Translated by you or the manufacturer (GPSR Articles 11(4) and 19(d); LVD Article 8(4)) ## If you do nothing - **You cannot answer the authority in time** — The economic operator responsible must provide the authority, after a reasoned request, with all information and documentation needed to show conformity in a language which that authority easily understands (Regulation (EU) 2019/1020, Article 4(3)(b); LVD Article 8(9)). - **A report that does not cover your product** — If nobody reads the report, nobody notices that it names another model or records a failed test. An importer must ensure the manufacturer drew up the technical documentation before placing the product (GPSR Article 11(1)), and may not place it with reason to doubt conformity (Article 11(2)). - **Instructions in the wrong language** — Importers ensure that the product is accompanied by instructions and safety information in a language consumers easily understand, as determined by the Member State where it is made available (GPSR Article 11(4)). Customs suspend release where labelling required by Union law is missing (Regulation (EU) 2019/1020, Article 26(1)(b)). ## Questions ### Must the technical file be translated into Danish, German or French? Not as a rule. The file must be provided on request in a language the authority easily understands (Regulation (EU) 2019/1020, Article 4(3)(b)). The Commission's Blue Guide says the authority may accept another language, including a third language, and that translation requests should be limited to the relevant parts. Under the GPSR, an authorised representative's mandate must allow it to provide the documentation in an official language which the authority can understand (Article 10(2)(a)). ### Who pays for the translation? The law places the duty to supply the documentation on the economic operator, not the cost. Agree with the supplier who translates which parts, and put it in the contract. ### Is a machine translation good enough? For your own check of a report, it helps you find the model, the standards and the verdicts. For instructions and warnings that consumers rely on, have the text checked by someone who knows the language and the product. ### Does the declaration of conformity need translating? For low voltage equipment, yes: it is translated into the language or languages required by the Member State where the equipment is placed or made available (LVD Article 15(2)). ## Regulations involved GPSR, LVD ## 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. [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 3. [Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530) — EUR-Lex, 2026-10-04 4. [The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)) — European Commission, via EUR-Lex, 2026-10-04