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Language Requirements for the EU DoC for Software

You've crafted your EU Declaration of Conformity (DoC) for your app or game, meticulously listing all the required details. But in what language should it be? The Cyber Resilience Act (CRA) has specific rules here.

Member State Requirements Dictate​

Article 28, Paragraph 2, of the CRA states that the EU Declaration of Conformity "shall be made available in the languages required by the Member State in which the product with digital elements is placed on the market or made available on the market".

This means if you're selling your game in Germany, your DoC might need to be in German. If you're targeting the French market with your app, French would be required. If you are making your software available across multiple EU countries, you may need to provide the DoC in several languages.

One Language Broadly Understood​

To help ease the burden, especially for smaller developers, Recital 94 notes that "Translation costs related to mandatory documentation, such as the technical documentation and the information and instructions to the user required pursuant to this Regulation, and communication with authorities, may constitute a significant cost for manufacturers... Therefore, Member States should be able to consider that one of the languages determined and accepted by them for relevant manufacturers’ documentation and for communication with manufacturers is one which is broadly understood by the largest possible number of users".

While this is an encouragement to Member States, you'll still need to verify the specific language requirements for each EU country where you intend to market your software. Often, English is widely accepted, but it's not a universal guarantee for official documentation like the DoC.

Simplified DoC Language​

The same language principles apply if you're using a simplified EU Declaration of Conformity as per Annex VI. It, too, must be in the languages required by the market where the product is available.

Key Takeway​

Your software's EU DoC must be translated into the official language(s) of the EU Member States where you make your product available. Check each country's specific requirements.