Product Labeling Translation Requirements

Technical Translations of Product Labels

As was discussed in the previous post Document Translation Services, Product Liability and Non-English Speakers: Case Law, US case law is surprisingly vague in regards to whether or not a manufacturer is required to provide foreign language translations of product safety information. However, regardless of what case law says, in some cases labeling standards require manufacturers to provide specific information. Although these standards are not law in fact, courts will often view them as industry practice conclusive of what should be required as ‘adequate labeling’.

Starting in 1991, the American National Standards Institute published a list of voluntary standards in regards to product safety labeling.

According to ANSI Z535, images are not required but are considered acceptable and thus encouraged. More so, the standard specifically uses translation of foreign language labels as examples, although the actual content does not specifically cite foreign language translations as being ‘appropriate’.

Although not required by the standard itself, a subpart of ANSI Z535 does provide acceptable formats for foreign language versions of a safety label, which include image depictions of the information in addition to the foreign language translations. However, the subpart does not go so far as to indicate when foreign language translations should be provided. Instead, it states: “The selection of additional languages for product safety signs is an extremely complex issue. Experts suggest that nearly 150 languages are spoken in the United States and over 23 million Americans speak a language other than English in their homes.”

As ANSI Z535 is the leading safety label standard in the US, it is safe to say that US standards do not require the use of foreign language translations of product safety information, although it is encouraged.

Retailer and Government Action

That being said, the fact is that many manufacturers are providing foreign language translations of their product’s safety information. This of course raises the question of ‘why’?

The main reason comes from economics. With such pro free-trade regulations as NAFTA, including product safety information in English, French and Spanish allows a manufacturer to sell the product throughout North America. However, as this economic reason causes more and more manufacturers to adopt foreign language translations of their safety information, it is likely that a ‘state of the art’ may be raised despite the lack of a clear judicial, legislative or voluntary standard guidance or requirements.

In addition to this private sector led initiative, some government agencies have moved to require foreign language translations of certain products that fall under their given jurisdiction. For example, the US Consumer Products Commission has issued a rule requiring manufacturers of packaged charcoal to include a foreign language translation (in Spanish) of safety message clarifying the dangers of burning charcoal indoors.

Use Caution When Including a Foreign Language Label Translation

If one opts to include a foreign language translation of their product’s safety information, one should do so with caution. There is a slight possibility that a manufacturer may run some risk of liability it they voluntarily include a foreign language translated label if the label contains inadequate or ineffectively communicated information. Thus, it is always recommended to use a certified technical translator when translating product safety information into foreign languages.






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