Retention periods for end users
There’s absolutely no obligation for end users to keep manuals. However, it’s recommended to retain the documentation at least until the end of the warranty period, as manuals often contain information relevant to the warranty, and it would be a shame if you lost your right to claim because you were unaware of it. Others keep the manual until they no longer use the product. This is certainly not a bad idea. And then there are those who put the manual in a random drawer, then in a box where it can no longer be found until the next time they move! This type of retention is not really recommended.
Retention periods for manufacturers
So what are the rules on retention periods from the perspective of manufacturers? For them there are retention periods required by law. These are set out in the Machinery Directive 2006/42/EC as follows: “The technical file must be made available to the competent authorities of the Member States for at least 10 years following the date of manufacture of the machinery or, in the case of series manufacture, of the last unit produced.” Incidentally, this also applies to “partly completed machinery” (i.e., machinery that is only intended to be installed in other machinery, e.g., a hydraulic system).
Work is currently ongoing at EU level to replace the Machinery Directive, but it’s unlikely that the retention periods will be changed substantially in the new EU Machinery Regulation.
Is ten years the maximum retention period?
Even now, a retention period of ten years is not the maximum. In some industries, significantly longer retention periods are required. For example, the Medical Device Regulation (MDR) stipulates a 15-year retention period for implanted products. Even longer periods of retention, sometimes of up to 30 years, apply to nuclear plants.
So, there’s no simple answer to how long manuals should be kept for. Many manufacturers also still provide manuals in the download areas of their websites that are much older than the required ten years following the date of manufacture. If in doubt, that’s why it’s worth looking to see if a manual is still available online.