Context card
Internal and external technical documentation: what "external" really means
Does "external documentation" mean documentation that is published?
The short answer
No. In German practice (VDI 4500) and in EU product law, "internal" and "external" say who keeps a document: internal documentation stays with the manufacturer as evidence, external documentation leaves the manufacturer and goes to operators and users. Whether a document is also public is a separate decision: most external documentation is handed over under contract or behind a login and is never on the open internet.
For: Technical writers, documentation managers, roll-out and service teams, regulatory and safety engineers
Key points
- Internal documentation (design data, calculations, test reports, risk assessment, the technical file) stays with the manufacturer and proves what was done.
- External documentation (instructions, maintenance and service manuals, handover documentation) goes with the product to operators and users.
- The internal file contains a copy of the external documentation: the Machinery Regulation lists the instructions for use in the technical documentation of Annex IV.
- "External" has three meanings in practice: handed over to the operator, restricted to a group (service staff, a customer portal), or public on the internet.
- Operators write documentation of their own, such as the employer’s Betriebsanweisung; it is neither the manufacturer’s internal nor its external documentation.
- Four questions sort any document: what does it do, who is it for, who writes and keeps it, and who can access it?
The context
Two lines that are often confused
Technical documentation is traditionally divided by where a document stays. VDI 4500 Blatt 1 calls everything the manufacturer creates and keeps for its own records and as evidence of compliance internal, and everything that goes to the users of the product external. EU machinery law draws the same line: the technical file is kept at the disposal of market surveillance authorities, while the instructions for use accompany the machine (Machinery Directive 2006/42/EC until January 19, 2027; Machinery Regulation (EU) 2023/1230, Article 10(7) and Annex III, section 1.7.4, from January 20, 2027).
Neither line says anything about publication. Roll-out teams call their commissioning and handover documentation "external" because it is client documentation, yet it is never public. Many manuals are not on the internet either: they are external only because they leave the manufacturer.
Three meanings of "external"
| Meaning | What it says | Examples |
|---|---|---|
| Handed over | The information leaves the manufacturer and goes to the operator who bought the product | Operating manual, handover and as-built documentation, spare parts lists |
| Restricted | Only a defined group can access it, on the operator's site or in a portal | Service manuals for qualified staff, customer-specific documentation, documents under a non-disclosure agreement |
| Public | Anyone can read it | Manuals for download, product pages, public e-IFU portals |
Four questions instead of two words
- Function: does the document prove (conformity, evidence), enable (use, maintenance, service) or govern (the operator's own rules)?
- Audience: authorities, internal roles (R&D, PLM, regulatory, safety, quality), the operator's staff, or the public?
- Author and keeper: manufacturer, supplier, integrator or operator?
- Access: manufacturer only, handed over under control, restricted, or public?
"Internal" and "external" then become shorthand for one answer to question 3 and 4, not a statement about confidentiality. The information for use is external by function and audience, and a copy of it is part of the internal file at the same time.
The operator's own documentation
Operators turn the manufacturer's information into instructions of their own for their staff, such as the employer's Betriebsanweisung in Germany. That documentation is written on the operator's side and stays in the guarded environment of the production site. Confidentiality never changes what the manufacturer has to supply to the user.
Questions readers ask next
- Is a service manual that only service technicians receive internal or external documentation?
- External: it leaves the manufacturer. Its access is restricted, but that is a question of access, not of internal versus external.
- Does the instruction handbook have to be published on the internet?
- Being external does not mean being public. Where instructions are supplied digitally, the Machinery Regulation sets conditions so that the user can download and access them; it does not turn them into public web content.
- Why does the technical file contain the instructions?
- Because the manufacturer has to show what information it gave users. The external documentation is therefore also part of the internal record.
Sources
- VDI 4500 Blatt 1: Technical documentation – Definitions and legal basics — VDI, 1 June 2006
- Regulation (EU) 2023/1230 on machinery — EUR-Lex, 29 June 2023
- IEC/IEEE 82079-1:2019 Preparation of information for use (instructions for use) of products – Part 1 — IEC, 29 May 2019
- § 12 BetrSichV Unterweisung und besondere Beauftragung von Beschäftigten — Bundesministerium der Justiz, 2 October 2026
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