English: "‘producer’ means any manufacturer, importer or distributor that on a professional basis places products on the market of a Member State."

German: „Hersteller" jeden Erzeuger, Einführer oder Händler, der gewerbsmäßig Produkte in einem Mitgliedstaat in Verkehr bringt.

That's the same rule, and in both of them the trigger is placing a product on the market, not making one.

Here's the funny thing. English puts the broad term on top: a producer is the class, and a manufacturer is one of three roles inside it. German inverts that. The class is Hersteller, in ordinary German, precisely the one who manufactures, while the manufacturing role inside the definition is Erzeuger. The everyday word for the narrow job has been promoted to name the whole class.

Neither text is "wrong"; both were adopted, and nobody who reads through to the end of the definition is going to get it wrong. But definitions get lost. Erweiterte Herstellerverantwortung is what reaches the trade press, the internal mail, and the slide that decides whether this directive is anyone's problem.

Now these are two potential problems with radically different downsides. A German contract manufacturer sees "Hersteller," assumes the obligation is theirs, and is wrong; they place nothing on the market. That costs them a meeting, where they get to hear the good news. However, when an importer or a distributor sees "Herstellerverantwortung," they think "we manufacture nothing," and conclude "not a problem." This is disastrous. Importers and distributors are explicitly named inside the definition, and producers have to cover at least 80% of the treatment costs plus the entire cost of gathering and verifying the data.

Way back in 1982, the Court of Justice settled how to read this. Legislation "is drafted in several languages and...the different language versions are all equally authentic. An interpretation of a provision of Community law thus involves a comparison of the different language versions."

So the inter-language comparison is not a little extra diligence for a couple attaboys at the next performance review. It's the job. And no compliance team on earth reads all 24.

However, a machine can. Line the authentic texts up article by article, bind every defined term to its definition instead of its dictionary meaning, and flag every place where the ordinary sense of a word is in opposition to the rule it names.

That is what we build at Gitterdan GmbH.

If you have ever found out the hard way that an obligation in your language did not mean what it looked like it said, we would like to hear how you found out.