€170 Million in Paper Manuals: The EU Is About to Let Brands Go Digital-First

The European Union's Omnibus IV package proposes a "digital by default" approach to product documentation — paving the way for QR codes and digital guides to replace the paper manuals that nobody reads, everybody loses, and brands spend a fortune printing. Here's what's changing, what it means, and why the smartest brands aren't waiting.

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Somewhere in a landfill, there are millions of paper manuals that were never read. They were printed in 24 languages, folded into accordion shapes, packed into product boxes in a factory in Shenzhen or Wrocław, shipped across oceans, carried home by customers, and immediately thrown into a kitchen drawer — or directly into the recycling bin. Most were never opened. The ones that were opened were usually abandoned within minutes. And the ones that were kept were inevitably lost by the time the customer actually needed them.

This is the state of product documentation in 2026: a multi-hundred-million-euro annual expense that produces almost zero value for customers and generates nothing — no data, no engagement, no revenue — for brands.

The European Union is about to change that. And for brands that understand what's happening, the implications go far beyond saving on printing costs.

The Regulation: What "Digital by Default" Actually Means

On May 21, 2025, the European Commission published its Omnibus IV simplification package — a sweeping set of amendments to multiple EU product directives designed to reduce administrative burden, cut red tape for SMEs, and modernize product regulation for the digital age.

The headline provision for product manufacturers: instructions for use can now be provided digitally. Under the proposed "digital by default" framework, manufacturers would be permitted to deliver product documentation — including user manuals, instructions for use, and declarations of conformity — in digital format rather than printed paper. A QR code on the product or packaging, linking to the digital documentation, would be sufficient.

The Omnibus IV package amends provisions across multiple product directives, including those covering electrical equipment (Low Voltage Directive), electromagnetic compatibility (EMC), radio equipment, pressure equipment, lifts, and more. Combined with the EU Machinery Regulation (2023/1230) — which already explicitly allows digital instructions for machinery from January 2027 — the regulatory direction is unmistakable: the EU is building a legal framework where paper manuals are no longer the default.

There are important guardrails. Safety information that is essential for putting a product into service must still be provided on the product itself or in paper form. Consumers retain the right to request a free paper copy within a specified period. And for the Machinery Regulation specifically, products intended for non-professional users must still include essential safety information on paper.

But the core shift is seismic: for the first time, EU law is moving toward a framework where a digital manual — accessible via QR code — is the primary form of product documentation, with paper as the fallback rather than the default.

The Omnibus IV proposals are currently in interinstitutional negotiations between the European Parliament and the Council, with trialogue expected to begin in spring 2026 under the Cypriot Presidency. Adoption is expected within the standard 18-month legislative cycle — meaning the rules could take effect as early as 2027–2028, aligning neatly with the Digital Product Passport timelines already in motion.

The Cost of Paper: €170 Million and Counting

To understand why this matters, you need to understand how much paper documentation actually costs — not just in printing, but across the entire lifecycle of a manual.

APPLiA, the European trade association representing home appliance manufacturers (including Bosch, Electrolux, Whirlpool, Miele, and others), has calculated that the home appliance industry alone spends up to €170 million annually on printing user manuals and safety instructions. On top of that, roughly €20 million per year goes to printing paper energy labels — for approximately 100 million labeled appliances entering the EU market annually.

That's just home appliances. Expand the scope to consumer electronics, power tools, lighting, audio equipment, personal care devices, sporting goods, and the dozens of other product categories covered by EU product directives, and the total industry-wide cost of paper documentation runs into the hundreds of millions.

And printing is only one component of the cost. A realistic accounting of paper manual expenses includes:

Translation. EU regulations require that product manuals be provided in the official language of every member state where the product is sold. The EU has 24 official languages. Professional translation for technical documentation typically costs €0.10–€0.25 per word. A 5,000-word manual translated into 24 languages costs €12,000–€30,000 — per product variant. Companies with broad product lines can spend hundreds of thousands annually on translation alone.

Design and layout. Every translated version needs to be formatted, typeset, and proofed — a process that multiplies with every language and every product update.

Logistics and warehousing. Paper manuals need to be printed, stored, shipped to factories, and inserted into packaging — adding weight, volume, and complexity to the supply chain. For products shipped globally, different manual versions must be produced and routed to the correct regional markets.

Revision and obsolescence. When a product receives a firmware update, a safety notice, or a feature change, the paper manual is instantly outdated. There is no way to update a manual that's already in a customer's drawer. Companies either live with inaccurate documentation in the field, or they incur the cost of reprinting, redistributing, and replacing — an expense that most simply don't bother with.

Environmental impact. The paper, ink, solvents, and shipping associated with hundreds of millions of printed manuals generate a measurable carbon footprint — a footprint that runs directly counter to the sustainability goals that the EU's broader regulatory agenda is trying to achieve.

The irony is hard to miss: the EU mandates that brands print sustainability information on paper, creating waste in the process of communicating sustainability.

The Dirty Secret: Nobody Reads Them Anyway

The cost alone would justify a shift to digital. But the case becomes overwhelming when you consider the other side of the equation: the value paper manuals deliver to customers is close to zero.

The research is consistent and damning. Studies show that only about 25% of users read product manuals. In one survey, 46% of consumers said they never read the product manual before using a device, and 39% never consult the manual for product onboarding. A Gadget Helpline survey found that 64% of men don't read the manual before calling technical support — they call first, and try the manual as a last resort (if at all).

Academic research confirms the pattern. A seven-year study of 170 participants found that not only do most users avoid reading manuals, but they also don't use all the features of products they use regularly — features that the manual was designed to explain. Another study based on in-depth interviews with 25 subjects found that users are equally likely to ask a colleague or experiment on their own rather than consult documentation.

The reasons are intuitive. Paper manuals are generic (they can't be tailored to the specific user's situation), static (they can't adapt to what the user already knows), hard to search (try finding the one paragraph you need in a 60-page booklet printed in 6-point font), and physically disconnected from the product (you need the manual most when you've already lost it).

And then there's the most expensive consequence of all: product returns. Accenture research has found that up to 95% of returned electronics are not defective — customers simply couldn't figure out how to use them, or the product didn't meet expectations that better documentation might have managed. Even attributing a fraction of the industry's 20–30% e-commerce return rate to inadequate documentation represents billions in unnecessary reverse logistics costs.

Paper manuals don't just fail to help. They actively fail to prevent the most expensive post-purchase outcomes.

What Digital-First Documentation Actually Looks Like

So if paper manuals are expensive, wasteful, unread, and ineffective — what replaces them?

The answer isn't simply a PDF behind a QR code. That would be replicating the paper experience in digital format — and it would fail for the same reasons. The opportunity is to fundamentally rethink what product documentation means when it's delivered digitally.

A modern digital product guide is a dynamic, interactive, and intelligent experience that adapts to the customer's needs in real time.

It's specific, not generic. A digital guide can be tied to the exact product model, variant, and firmware version the customer owns. Instead of a 60-page booklet covering every SKU in a product line, the customer gets documentation that's relevant to their specific unit.

It's searchable and navigable. Customers don't read manuals sequentially. They have a question and they want an answer. Digital documentation supports natural-language search, structured navigation, and intelligent linking between related topics.

It's conversational. With AI-powered support agents, digital documentation can move beyond static text to interactive troubleshooting. Instead of reading a 12-step diagnostic flowchart, the customer describes their problem and gets a targeted response — complete with visual guidance, video walkthroughs, and contextual next steps.

It's updatable. When a firmware update changes a feature, or a safety notice needs to be communicated, digital documentation can be updated instantly — reaching every customer, including those who bought the product months or years ago.

It's measurable. Digital documentation generates data that paper never could. Which setup steps are customers struggling with? What questions are they asking most? Where in the onboarding flow do they drop off? Which features are they not discovering? This data feeds back into product development, support operations, and marketing — creating a feedback loop that paper manuals structurally cannot provide.

It captures the relationship. The moment a customer scans a QR code on their product, the brand has a direct digital connection to that customer — with their consent. That connection enables warranty registration, support access, accessory recommendations, replenishment reminders, and all the post-purchase engagement that turns one-time buyers into long-term customers.

The QR Code Engagement Opportunity

Skeptics will ask: "Will customers actually scan a QR code?"

The data says yes — increasingly so. QR code usage has surged since the pandemic, and scanning behavior is now habitual for most consumers. Industry data shows that 57% of consumers worldwide have scanned QR codes on food packaging to access product information. Across categories, the top reasons people scan QR codes include curiosity (39%), redeeming offers (36%), learning more about the product (30%), and — critically — finding instructions on how to use a product (28%).

Well-implemented QR campaigns on product packaging achieve scan-through rates of 14.9% on average, with best-in-class implementations reaching 25–30%. And QR codes on packaging have been shown to boost consumer trust by 40%, as customers associate the ability to verify product information with brand authenticity.

These numbers dwarf the engagement rates of paper manuals. When 46% of consumers never open a paper manual but 28% of QR scanners are specifically looking for usage instructions, the digital channel is already outperforming paper for its primary purpose — helping customers use the product.

And unlike paper, digital engagement is measurable, improvable, and monetizable.

The Convergence: Digital Manuals Meet Digital Product Passports

Here's where the strategic picture becomes especially compelling. The EU's Omnibus IV digital documentation provisions are arriving at almost exactly the same time as the Digital Product Passport requirements under ESPR.

Both require a QR code or data carrier on the product. Both create a digital layer tied to a specific physical product. Both demand structured, accessible, updateable information hosted online. And both are designed to persist throughout the product's lifecycle.

For brands, this means the infrastructure investment for one requirement serves the other. The QR code that links to your digital product manual can simultaneously link to your Digital Product Passport — and to warranty registration, support resources, accessory recommendations, and post-purchase engagement. One QR code. One scan. One platform. Multiple regulatory requirements satisfied, and a customer relationship initiated.

Brands that plan for this convergence now — building a unified digital product layer that serves documentation, compliance, and engagement — will spend once and benefit three times over. Brands that treat digital manuals and Digital Product Passports as separate compliance projects will spend twice and get less.

Who Moves First Wins

APPLiA's call to action is explicit: "Digital instructions and safety information are already common practice, though current legislation still obliges the home appliance sector to provide printed instructions and safety information with each unit." The trade body representing Europe's largest appliance manufacturers is pushing for digital manuals not as a future aspiration but as an overdue correction.

The legislative process is underway. The regulatory direction is set. The question isn't whether paper manuals will become optional for consumer products — it's when. And the brands that build digital-first documentation now will have several decisive advantages when that moment arrives.

They'll have tested and optimized their digital experience while competitors are still designing theirs. They'll have months or years of engagement data showing which content works, where customers struggle, and what drives conversion. They'll have established digital relationships with customers who are already accustomed to scanning the product and finding value. And they'll have a unified platform that satisfies documentation, DPP compliance, and post-purchase engagement requirements simultaneously.

The EU is about to make paper manuals optional. The smart brands have already made them obsolete.

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Sources

• Omnibus IV: The Digitalisation Opportunity Europe Cannot Afford to Miss — APPLiA
• APPLiA Proposal for Digital Manuals — Omnibus on Small Mid-Caps and Paper Reduction
• EU Omnibus IV: Towards a "Digital by Default" Era for Product Compliance — Linklaters
• From Paper to Pixels: The Digital Makeover of EU Product Legislation — Hogan Lovells
• EU Machinery Regulation 2023/1230 — Digital Instructions Provisions — iSAX
• The Lack of Effectiveness of Paper Manuals — Layerise
• Why Don't People Read the Manual? — ResearchGate
• 95% of Returned Gadgets Still Work — Engadget / Accenture
• QR Code Statistics for 2026 — QR Code Chimp
• QR Codes on Product Packaging: Engagement Benchmarks — Uniqode
• How Much Does a User Manual Cost? — Instrktiv
• EU Digital Product Passports and ESPR Compliance — Reconomy