Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas

RAMUNĖ VASKELAITĖ Institute of the Lithuanian Language TRANSLATING ABBREVIATIONS IN EUROPEAN UNION LEGAL ACTS: THE QUESTION OF CRITERIA KEYWORDS: letter abbreviation, syllabic abbreviation, proper name, common name, symbolic name. ABSTRACT In works that prescribe or convey language norms, abbreviations are usually discussed as objects at the level of orthography; however, even the brief treatment of them in sections on spelling makes clear that such shortened names are not confined to the level of orthography. Nevertheless, other aspects are not discussed in depth either in sections on spelling or, still less, in works covering other levels of language. As abbreviations become increasingly numerous, including non-Lithuanian abbreviations whose formation, inflection and spelling features only partially coincide with those discussed in sections on Lithuanian spelling, various uncertainties arise in usage. This article examines one of them—the translation of non-Lithuanian abbreviations—drawing on translations of European Union legal acts into Lithuanian. INTRODUCTION Works that prescribe norms for Standard Lithuanian, as well as those in which norms are conveyed rather than prescribed (textbooks, reference books, and the like), show that abbreviations are treated as objects at the level of orthography: both in the normative Lithuanian Spelling and Punctuation (hereafter LKRS), BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 2 doi.org/10.35321/bkalba.2020.93.14 they are mentioned in spelling sections even in works covering other levels of language. Nevertheless, the brief discussion of abbreviations presented in those sections makes it clear that they are not related solely to the level of spelling. For example, the section Alphabetic abbreviations of names, or abbreviations in LKRS (1992: 73–74) shows that abbreviations can be declined. After listing those formed from the initial letters of the words in a name, it notes that some of them are declined when necessary, with the endings written after a hyphen or an apostrophe (TASS-o or TASS’o report), while abbreviations formed from several initial letters or syllables (Elfa and Kuzbasas) are said to be frequently declined. This also touches on the structure of abbreviations: some are formed from initial letters, others from several initial letters or initial syllables. The latter are prescribed a different spelling from alphabetic abbreviations: only the first letter is capitalized, as with proper nouns, while elsewhere they are treated as symbolic names: “Euratomas”, “Eurostatas”, “Unikodas”, and so on (Kazlauskienė 2008: 73). Thus, the relationship between abbreviations and names or symbolic names is also a relevant issue. Some spelling sections mention borrowed or international abbreviations (Linkevičienė 2013: 29), making clear that abbreviations can differ in origin. Thus, even brief spelling sections touch on various aspects, but do not discuss abbreviations in greater detail. This is understandable—the purpose of spelling sections is not to do so. However, abbreviations are not discussed at all in prescriptive works covering other levels of language, and so these aspects of them remain largely unexamined 1. Perhaps a more detailed discussion would not be too 1 Answers concerning the use of individual abbreviations are provided in the State Commission of the Lithuanian Language’s Consultation Bank: http://www.vlkk.lt/konsultacijos. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 3 doi.org/10.35321/bkalba.2020.93.14 necessary if not for the abundance and variety of abbreviations, which continue to grow as the circumstances in which the Lithuanian language exists undergo fundamental change: many are used in English, at least in administrative and scholarly texts, and the conventions for their formation, spelling, and inflection in that language do not match those described in Lithuanian spelling sections. This causes considerable uncertainty in usage. Attention has been drawn to these uncertainties. For example, in two publications Gintautas Grigas discussed the uncertainties caused by English abbreviations spreading in computer terminology (Grigas 2006, 2011), while the author of this article addressed those raised by non-Lithuanian abbreviations used in economic texts (Vaskelaitė 2011). A study of symbolic names identified uncertainty about the relationship between abbreviations and symbolic names (Vaskelaitė 2019: 10–15, 40–45), while Ruta Marcinkevičienė, viewing abbreviations as acronyms, raised the relationship between an abbreviation and a word as a problematic issue in a 2003 article. At the end of that article, she stated that “there are many questions concerning acronyms, and they need to be answered quickly” (Marcinkevičienė 2003: 92); yet, five years later, an article by another author concluded that “these matters must be considered as soon as possible and recommendations provided” (Kazlauskienė 2008: 74). The translation of acronyms is mentioned as one of the issues that must be considered: “Language planners should consider which of them to translate and which to leave untranslated” (Marcinkevičienė 2003: 92). A. Kazlauskienė mentioned the issue of adapting abbreviations to Lithuanian, but likewise specified it as the question of “which abbreviations should be translated and which should not” (Kazlauskienė 2008: 74). Nevertheless, the issue is merely raised; it has not been examined from the perspective of language norms. From this perspective, it has been touched on only in a couple of G. Grigas’s publications (2006, 2011), which focus on specific abbreviations—computer terminology—and mention the translation of abbreviations only as one way of rendering non-Lithuanian abbreviations in Lithuanian texts. Abbreviations are mentioned all the more in the context of translation methods in works on translation theory and practice, such as Lionginas Pažūsis’s comprehensive volume Kalba ir vertimas—here they BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 4 doi.org/10.35321/bkalba.2020.93.14 minimos aptariant eksplicacinio pobūdžio pakeitimus ar pridėjimus (Pažūsis 2014: 550–553; 557–558). In this article, published in a journal that presents research on language norms and usage, the translation of abbreviations will, naturally, be considered not from the perspective of translation theory, but as an object of Lithuanian standard-language norms and usage. From this perspective, the relevant issue is that of the criterion. Works that prescribe or describe language norms acknowledge that Lithuanian texts may also use non-Lithuanian abbreviations, but they often do not specify a criterion for when a Lithuanian abbreviation should be used and when a non-Lithuanian one should be used. A certain criterion is set out in a resolution of the VLKK that has normative force, but it is fairly general, applies only to alphabetic abbreviations, and is not oriented towards translated texts. This criterion is difficult to apply in translated texts, and when difficulties arise in usage, people look for their own criteria. This analysis will focus on those criteria. The usage selected for analysis consists of translations of European Union (hereinafter, EU) legal acts. This does not mean, however, that the abbreviations examined will be confined to a narrow field, since EU legal acts use many abbreviations that are widespread, or are becoming widespread, in other areas of administrative language as well, and in scientific and journalistic texts, and in general usage. Even those that are more narrowly used are nevertheless formed by one of the methods of formation mentioned in spelling sections or discussed in articles. Still, although the abbreviations under discussion will not be specific to a particular field, their area of use has certain distinctive features that may influence patterns of abbreviation use. Therefore, the aim of the article will not be to examine the translation of abbreviations in general, but their translation in EU legal acts. The aim of the article is to determine which criterion or criteria govern the use of a Lithuanian or non-Lithuanian abbreviation in translations of EU legal acts. The objectives are to select from the chosen BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 5 doi.org/10.35321/bkalba.2020.93.14 sample all alphabetic and syllabic abbreviations and, by comparing Lithuanian and non-Lithuanian ones from various linguistic perspectives (by length, type of name abbreviated, the object named, method of abbreviation formation, etc.), to determine which factor or factors influence the choice of a Lithuanian or non-Lithuanian abbreviation. Assessing abbreviations in a separate section from each perspective should bring the main criterion or criteria to light, and these will be summarized in the conclusions. Such an analysis is relevant to language standardization, but should also be useful to text producers, editors, and translators—in short, to all creators and users of abbreviations. Although the formulation of the normative criterion refers not to the translation of abbreviations but to the translation of names and the formation of an abbreviation from a translated name, while elsewhere the discussion concerns the use of abbreviations, using such terms in this article would be not only inconvenient but also inaccurate, since they imply a different object of study. For these reasons, the term translation of abbreviations will be used, especially since it has already appeared in articles by R. Marcinkevičienė, A. Kazlauskienė, and G. Grigas; the corresponding terms criteria for translating abbreviations, translated (rendered) abbreviations, untranslated (unrendered) abbreviations. will also be used. Of course, however, the term translation of abbreviations will not cover every possible way of rendering abbreviations used in the source language in the translated text, but only whether a non-Lithuanian abbreviation is replaced with a Lithuanian abbreviation or left unchanged. In this respect, the term differs from the one used in translation-theory works, where translation is understood as replacing a text in one language with a text in another while retaining the same or nearly the same meaning, scope, and other methods of rendering an abbreviation—omission, substitution, addition, and so on (Pažūsis 2014: 550–553; 557–558). Such methods also occur in the usage under study, but they will not be the subject of this article. Another key term in this article—abbreviations—which is likewise not used uniformly by everyone, will be used as in the author's earlier articles (Vaskelaitė 2011, 2020), that is, BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 6 doi.org/10.35321/bkalba.2020.93.14 it will cover abbreviated names, rather than word shortenings (doc., pirm., apyl., vlš.) or symbols (km, h, kW, Eur, EUR, €)2. 1. USAGE CHARACTERISTICS Legal acts are, of course, not works by individual authors, but texts produced by institutions, so their drafting should be regulated and coordinated. This is also evident from the many resources for drafting or translating texts published on the websites of EU institutions. However, EU legal acts are drafted not by a single institution but by several (the European Parliament, the Council, the European Commission, etc.), so coordination takes place not only within institutions but also between them. One source demonstrating interinstitutional coordination is the Interinstitutional Style Guide (hereinafter, the Style Guide), which is intended both for those working on the Official Journal3, where EU legal acts are published, and for those preparing other publications issued by EU institutions. The Official Journal also publishes Lithuanian translations of legal acts, so it is understandable that the provisions set out in the Style Guide must be followed not only by those drafting texts but also by translators. Those provisions cover requirements concerning both the structure of legal acts (Part One) and the preparation of publications (Part Two), as well as matters of spelling and punctuation. For instance, Part Three sets out rules common to all official EU languages, covering spelling matters such as the citation of footnotes and the writing of addresses or telephone numbers, as well as matters at other linguistic levels, such as the instruction that in legal documents the nominative form of the name of the common EU currency should be written euro (one euro). Part Four of this guide, which is available in 24 official languages 2 By the way, one of the previously published articles also provides a detailed overview of the use of the term (Vaskelaitė 2011: 61–66). 3 The full title is Official Journal of the European Union. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 7 doi.org/10.35321/bkalba.2020.93.14 The section of the published guide already sets out the rules of the national language; in the Lithuanian version, these are the rules of Lithuanian spelling and punctuation. The introductory sections of the LV make clear that it is not only coordinative but also regulatory in nature: “The general rules established in the Guide are, in essence, superior to rules established or previously applied elsewhere; they must be applied at every stage of the written procedure.” The description of IATE, the terminology database used by EU translators, reveals an aim that is more coordinative than regulatory. It shows that terms are entered into the database by translators (and terminologists) themselves, and that they are free to enter terms that, “in their opinion, are useful to them in their work” (FAQ 2020). Use of the database is also recommended with relative flexibility, taking account of the reliability assigned to a term: “it is important to assess each decision on its merits. If a term is marked as having low reliability and no additional information is provided about it, you should probably not rely on it blindly. On the other hand, if a definition of the term, reliable references and other information are provided, you can probably trust it. When assessing the reliability of terms, use your own judgement and the criteria mentioned above” (FAQ 2020). Another coordinative measure or resource4 is aimed directly at translators. This is the Guide for Translation into Lithuanian by the EU Institutions (hereinafter VV), which is published not only electronically but also as a separate volume5. Like Part Four of the LV, the published volume mainly covers matters of Lithuanian spelling and punctuation; however, as stated in its introduction, it is a continuing work and will be expanded (VV 2014: 6). 4 The introduction reveals the aim of interinstitutional coordination: “the translation departments or units into Lithuanian of many EU institutions have prepared translation guides, guidelines or instructions of varying scope. To share the experience gained, harmonise the positions of all the institutions and present what is genuinely relevant to translators, work began on preparing a common Guide for Translation into Lithuanian by the EU Institutions” (VV 2014: 6). 5 Guide for Translation into Lithuanian by the EU Institutions, Luxembourg, 2014. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 8 doi.org/10.35321/bkalba.2020.93.14 Thus, at the interinstitutional level, not only the preparation of texts but also language matters are coordinated and regulated; at the same time, it becomes clear that these rules are not established without translators’ knowledge. For instance, as stated in its foreword (VV 2014: 5), the VV has been agreed upon by translators (and editors and lawyer-linguists) from all EU institutions. The LV is described as “the unique result of the coordination of linguistic versions”; more specifically, it is stated that an Interinstitutional Steering Committee was set up to prepare it, appointing representatives from each institution and language, who work under the guidance of the coordination group operating within the Publications Office. Nevertheless, although only representatives are mentioned, everyone (authors, editors, lawyer-linguists, terminologists and proofreaders), including translators, is invited to submit proposals. All users of the LV are invited to express their views, send useful information, and report any error or omission. Without input from EU institution staff, it would be more difficult to determine the extent to which Lithuanian-language specialists may influence the preparation of all this material. The VV introduction shows that it was prepared by the Lithuanian Language Department of the European Commission’s Directorate-General for Translation and considered by a special subcommittee of the VLKK (VV 2014: 6); thus, the publication was both prepared and reviewed by Lithuanian-language specialists. The introduction also states that Part Four of the LV, which likewise covers Lithuanian spelling and punctuation rules, was prepared in close cooperation with the Lithuanian Language Department. However, it is unclear to what extent Lithuanian-language specialists can influence the other parts of the LV. The LV introduction shows that the requirements of different languages were harmonised in these guides, prepared in the 24 official EU languages, and describes this as a difficult task: “Harmonising the linguistic requirements applicable to such a large number of languages seemed utopian. Nevertheless, this difficult task was completed successfully, and its result – the Guide to the Preparation of Publications of the Institutions – is available online in 24 official languages.” It also becomes clear that the guide was prepared in accordance with “the principle of multilingualism of the institutions, under which texts prepared in all official languages must not only conform to the characteristics of each language, but also BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 9 doi.org/10.35321/bkalba.2020.93.14 be comparable.” This principle of multilingualism, and the need to harmonise the requirements of different languages, is probably the main distinctive feature of the usage under consideration, distinguishing it from legal acts or other Lithuanian texts prepared in Lithuania, where there is no need to observe such principles. All the sources mentioned address the use of abbreviations. The LV, for example, has a section entitled Abbreviations and acronyms, which divides abbreviations into acronyms (or initialisms) and syllabic abbreviations. Abbreviations are also included in other sections, for example, in lists of the official names of EU institutions and bodies; the LV appendices also contain a list of principal acronyms and abbreviations (Appendix 2). The VV, which is focused on translation, sets out rules for writing syllabic abbreviations. Abbreviations are also included in IATE, and the unabbreviated names provided alongside them show that some are Lithuanian, while others are formed from non-Lithuanian names. More recently, another resource devoted directly to the translation of abbreviations was published—Practice and Recommendations for the Use of Abbreviations in EU Documents Translated into Lithuanian (hereinafter SVPR). It lists ways of using abbreviations in EU documents and even formulates criteria for choosing between a Lithuanian and a non-Lithuanian abbreviation. However, these recommendations do not constitute a normative work; rather, they are a working resource for translators. Accordingly, the criteria formulated are more akin to guidelines and pointers presented in a way that is convenient for translators, and from a linguistic perspective they seem to duplicate one another and are not all linguistic in nature. The date in the heading—2020 04 08—indicates that the resource was published recently, while the heading itself—practice and recommendations—suggests that it may also summarise practice already followed before then. As can be seen, there is more than one resource governing the use of abbreviations in EU institutions; thus, in the absence of EU institution translators or text drafters, it would be difficult to determine what procedure they BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 10 doi.org/10.35321/bkalba.2020.93.14 used, which is given precedence, and so on. Moreover, more instruments are published than those listed, for example, Joint Practical Guide of the European Parliament, the Council and the Commission for persons involved in the drafting of European Union legislation6, Joint set of rules for the presentation and drafting of acts adopted under the ordinary legislative procedure7, databases, and terminology dictionaries8. Thus, the tendencies in the use of abbreviations in texts translated by EU institutions are probably the result of a combined or hierarchical application of various instruments and criteria. It is therefore best to base the analysis on actual usage, that is, on legal acts translated into Lithuanian. Such documents are available in the EU legal acts database EUR-lex9. For this study, 100 of the most extensive legal acts—regulations and directives—are selected from it, with perhaps a somewhat greater focus on the fields of economics and finance. The sample consists of regulations and directives from 2000–2020, with an effort made to include documents from each year so as to establish whether the use of abbreviations has changed. All alphabetic and syllabic abbreviations are extracted from the sample and analyzed from various linguistic perspectives, comparing their use with that in the corresponding legal acts in English (which are also published in the EUR-lex database). Not all the documents may have been translated from English, but the English texts reveal the origins of almost all the abbreviations used; therefore, somewhat provisionally, English will be referred to as the source language in the text. The origins of only a few abbreviations could not be established on the basis of these texts, so the relevant legal acts in French (also published in the EUR-lex database) were also consulted to identify their source. By the way, this article covers only abbreviations formed from initial letters and syllables, since it is considered that 6 https://eur-lex.europa.eu/content/techleg/KB0213228LTN.pdf 7 https://www.consilium.europa.eu/media/21451/joint-handbook-lt-may-2016_2017_04_26_def.pdf 8 https://ec.europa.eu/info/resources-partners/translation-and-drafting-resources 9 https://eur-lex.europa.eu/homepage.html?locale=lt BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 11 doi.org/10.35321/bkalba.2020.93.14 Questions concerning the translation, as well as the classification, of other types (formed by incorporating other abbreviations, words, numerals, symbols, and so on) should be the subject of a separate article. 2. PREVALENCE CRITERION The normative criterion is formulated in the VLKK resolution On Lithuanian Spelling and Punctuation (VLKK 1997), in the section On Alphabetic Abbreviations. This section, admittedly, focuses primarily on the transliteration, or transcription, of abbreviations: its first subparagraph stipulates that “[N]on-Lithuanian (international) abbreviations consisting of Latin letters are to be written in Lithuanian texts as they are written in the original language”; the second states that “[A]bbreviations in languages using non-Latin scripts are to be transcribed using Lithuanian characters.” A third subparagraph is also provided, however, adding: “If names in other languages are widely used in translation into Lithuanian, alphabetic abbreviations are formed from their Lithuanian version.” Thus, the criterion focuses on the prevalence of the name: if a name is widely used in translation into Lithuanian, its abbreviation should be Lithuanian; otherwise, it may be retained in the form used in the original language. However, the section title indicates that this formulation applies only to alphabetic abbreviations, as confirmed by the examples provided. In 2000, a separate resolution on abbreviations was also adopted, but it merely lists six abbreviations of names of the European Communities and of areas of cooperation among the Member States of the European Union, and states that these are to be used in Lithuanian in documents and other texts prepared in Lithuanian (VLKK 2000). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 12 doi.org/10.35321/bkalba.2020.93.14 The criterion based on widespread use is rather general in nature. After all, there is no way to determine whether a name is widespread, let alone whether it is widely used. Thus, as the author has already noted in an article on the dissemination of research, subjectivity in making such a determination is unavoidable even in usage (Vaskelaitė 2002: 4). The wording “widely used translated into Lithuanian” also allows for interpretation. It would seem to indicate that the reference is not to the name itself, but to the widespread use of the name translated into Lithuanian; yet names with a direct meaning should generally all be translated into Lithuanian, unless they are personal or place names. On the other hand, it is up to the translator whether a name becomes widespread in its Lithuanian translation (and EU legal-act translators also determine which abbreviation for that name becomes widespread, since Lithuania is obliged to apply translated EU regulations and transpose directives into national law10). Thus, this brief wording was probably not intended to refer to translated texts, still less to texts translated by European institutions. It is also possible to interpret it another way, although the wording does not suggest this: only abbreviations that are not used without the full names should be translated, whereas if only an abbreviation is widespread and the full name is not, the abbreviation may be given in the original language. Translations of EU legal acts show that almost all names are translated—both proper and common names—with the exception of symbolic ones. In most cases, the full name appears first in the original, followed by the abbreviation in parentheses; thereafter, the abbreviation is used in place of the full name, for example: The harmonised index of consumer prices (HICP) is designed to measure inflation in a harmonised manner across Member States. The Commission and the European Central Bank (ECB) use the HICP in their assessment of price stability in the Member States under Article 140 of the Treaty on the Functioning of the European Union (TFEU). The Lithuanian text is translated accordingly: 10 https://ec.europa.eu/info/law/law-making-process/applying-eu-law BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 13 doi.org/10.35321/bkalba.2020.93.14 Harmonised Index of Consumer Prices (hereinafter “HICP”) is designed to ensure that inflation is measured in a harmonised manner in all Member States. The Commission and the European Central Bank (hereinafter “ECB”) use the HICP when assessing price stability in the Member States under Article 140 of the Treaty on the Functioning of the European Union (hereinafter “TFEU”) Article 140. In the rare cases where the abbreviation appears first in the original, followed by the full name in parentheses, as in The Commission report on the second phase of the SLIM exercise (Simpler Legislation for the Single Market) recommended that a study be carried out to determine, the same order is preserved in the translation: In the Commission report on the second phase of the SLIM (Simpler Legislation for the Single Market) exercise, it is recommended that a study be carried out. Several abbreviations, namely EU, EC, IT, OJ, JHA, EEC, ISO, SMS, are used in English texts without the full name being given; they are used in the corresponding Lithuanian texts as well, although some (EU, EC, IT, OJ, JHA and EEC) are given in translation. Thus, the original is followed. However, an abbreviation used in the original may be omitted in the translation or expanded by adding a generic word11, but if it does not appear in the original, no abbreviation is introduced in the Lithuanian text. In other words, translators are not entirely free to introduce, create and use abbreviations, as authors are. This is another reason why this article discusses the translation of abbreviations, rather than their formation from names that are or are not translated. Thus, names are translated, but some abbreviations are translated while others are retained as they appear in the original; compare: The European System of Financial Supervision (hereinafter “EFSF”) should aim to remedy these shortcomings; The Community eco-management and audit scheme (hereinafter “EMAS”); the “Copernicus” programme should be considered a European contribution to the development of 11 This is also mentioned in the SVPR, for example, which states that if an abbreviation occurs only once or a few times in the source document, it is preferable to use the unabbreviated phrase in the document translated into Lithuanian, or that an appropriate generic word may be added to the abbreviation (SWIFT code, NACE classification), etc. (SVPR 2020: 8). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 14 doi.org/10.35321/bkalba.2020.93.14 Global Earth Observation System of Systems (hereinafter – GEOSS), which is being developed by the Group on Earth Observations (hereinafter – GEO)12. Comparing these examples, one might readily conclude that a standardising criterion is being applied, i.e. the abbreviation for a widely used name is given in Lithuanian (EFPIS), while for a less widespread name (as the context shows—the Community eco-management and audit scheme is only being established) the form used in the English text is retained (EMAS); non-Lithuanian abbreviations are also retained when their prevalence is unclear (GEOSS, GEO). However, this is contradicted by the titles of legal acts alone, which name the bodies being established. The names of such bodies are equally unfamiliar, yet non-Lithuanian abbreviations are given only for some of them, for example: Regulation (EU) 2018/1971 of the European Parliament and of the Council of 11 December 2018 establishing the Body of European Regulators for Electronic Communications (BEREC) and BEREC support agency (BEREC Office); Regulation (EU) 2018/1240 of the European Parliament and of the Council of 12 September 2018 establishing a European Travel Information and Authorisation System (ETIAS); Regulation (EU) 2019/1238 of the European Parliament and of the Council of 20 June 2019 on a pan-European Personal Pension Product (PEPP)13. In other cases, Lithuanian abbreviations are provided from the outset, before the name has had time to become widespread, for example: Regulation (EC) No 1211/2009 of the European Parliament and of the Council of 25 November 2009 establishing the Body of European Regulators for Electronic Communications (EERRI) and establishing the Office; Regulation (EU) 2017/1601 of the European Parliament and of the Council of 26 September 2017 establishing the European Fund for Sustainable Development (EDVF), EDVF Guarantee and EDVF Guarantee Fund; Regulation (EU) 2017/2226 of the European Parliament and of the Council of 30 November 2017 establishing an Entry/Exit System (AIS). 12 Here and below, only the coherent clause of a sentence relevant to the use of the abbreviation is quoted; omitted sentence beginnings or endings are not marked by ellipses. Since the specific source of an abbreviation is not relevant to this study, it is not identified when an example is given; a list of all sources used is provided at the end of the article. 13 Headings, like the quoted sentences, are also presented in abbreviated form. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 15 doi.org/10.35321/bkalba.2020.93.14 However, the widespread use of the abbreviation for a name does not change. Material spanning a 20-year period was used for this study, and the names of entities established during that period might be expected to have become widespread; some are used extensively in other EU institutional legal acts. Yet this sample, at least, shows no shift from non-Lithuanian to Lithuanian abbreviations. There were only three exceptions, and even these suggest the opposite tendency. In European Parliament and Council regulations from an earlier period, for example Regulation No 575/2009 adopted in 2013, the Lithuanian abbreviation EDPPI (European Insurance and Occupational Pensions Authority) was used, whereas in more recent regulations, for example Regulation 2019/1238 adopted in 2019 or Regulation 2020/1503 of 2020, the abbreviation of English origin EIOPA is used. The name of the European Asylum Support Office was abbreviated as EPPB in Regulation No 604/2013 of 2013, while Regulation 2019 already abbreviates it as EASO. The use of another abbreviation suggests fluctuation: Directive 2011/61/EU of 2011, Regulation No 806/2014 of 2014, and Regulation 2019/1156 of 2019 use EVPRI (European Securities and Markets Authority), but documents from different years also use ESMA (Regulation No 909/2014 of 2014, Directive 2020/1504 of 2020). It is true that the most recent legal acts (Regulation 2020/1503 of 7 October 2020 and Regulation 2020/873 of 24 June 2020) use ESMA, so in this case too there is a shift to an abbreviation of English origin. Of course, the sample analysed is no substitute for the entire EU legal acts database, but it sufficiently reveals a tendency for abbreviations in legal acts to be used consistently. The aim of achieving this uniformity is also indicated by the working tools already discussed: they publish lists of abbreviations common to EU institutions, with uniform abbreviations and uniform rules. A separate check was also made of 20 regulations and directives adopted after the publication of SVPR (after 2020 04 08), and no changes in abbreviation use were found in them either; naturally, however, a longer period would be needed for such changes to emerge (and for more directives and regulations to be adopted). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 16 doi.org/10.35321/bkalba.2020.93.14 Understandably, the names used in EU legal acts are not limited to those of entities being established, so the criterion of widespread use might seem to affect decisions about their abbreviation. The fact that such a criterion may have some influence is suggested, it would seem, by SVPR, which lists 7 criteria for selecting abbreviations (source, tradition, recognisability, symbolic significance, prevalence, brevity and phonetic structure, and the entity denoted), with tradition mentioned second. It is true that this criterion is not explained; only a couple of examples of Lithuanian and non-Lithuanian abbreviations are given (ESBO – Organization for Security and Co-operation in Europe, PSO – World Health Organization, and NATO, UNESCO), and it is difficult to tell from these whether the tradition of using an abbreviation in general is meant, or its tradition in EU legal acts. In any case, source is mentioned as the first criterion, and its elaboration makes clear that, when translating abbreviations, priority must be given to founding documents, other legal acts, instructions from competent entities, or official statements. This is also emphasised in the note: “Abbreviations for the names of European Union agencies and bodies are used as indicated in the founding documents. Since not all agencies’ or bodies’ abbreviations are given in the founding documents, it is recommended that they be checked in the IATE database, which provides the latest information and instructions or official statements from competent entities” (SVPR 2020: 12). This makes clear the importance of the metalinguistic factor: abbreviations should be used in the form specified by competent entities and used in documents. This does not mean, however, that they must be non-Lithuanian. For example, in LV, which translators are also instructed to follow (SVPR 2020: 12), some name abbreviations are non-Lithuanian (EASO – European Asylum Support Office, EUIPO – European Union Intellectual Property Office), while others are of Lithuanian origin (EIB – European Investment Bank, EAA – European Environment Agency, EIVT – European External Action Service). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 17 doi.org/10.35321/bkalba.2020.93.14 Incidentally, prevalence is also mentioned as a criterion in SVPR (as the fifth), but it is formulated as the prevalence of an abbreviation, rather than a name, and as prevalence in other languages, rather than in Lithuanian: “A borrowed abbreviation may be selected if it is widely used in other languages (according to IATE data)” (SVPR 2020: 13). This criterion is not formulated in works that set norms for the Lithuanian language, but the context in which the normative criterion discussed above is formulated allows for some interpretive possibilities. The first subpoint in the aforementioned section On letter abbreviations states that non-Lithuanian (international) abbreviations made up of Latin letters are to be written as in the original language; if this subpoint is not linked to the third, one could conclude that all non-Lithuanian (international) abbreviations may be written this way. Even if, in this case, the parentheses indicate not that the concepts are being equated but that the meaning is being specified (that of “non-Lithuanian” abbreviations, only “international” ones are intended), the term international abbreviation is nevertheless not explained either in this resolution or elsewhere. Left unexplained, it leaves room for various interpretations, including equating an international abbreviation with an international word, of which there is now more than one conception. For example, in the Encyclopedia of the Lithuanian Language the term international words is explained as “borrowings accepted into the general language (not regarded as barbarisms), whose foreign origin is clearly confirmed by at least some of the major languages of international communication (or classical languages), and which show no unmistakable traces of borrowing from any neighbouring language” (LKE 2008: 547)14. If this analogy were applied to abbreviations, it would indeed follow that the use of an English abbreviation in a few languages is enough for it not to be translated, although, for example, LKRS cites only the abbreviations PS or P.S. (Latin post scriptum), NN or N.N. (Latin nomen 14 In practice, this conception has already been applied in the latest dictionary of international words (TŽŽ 2013). P. Zemlevičiūtė (2018: 153–154) provides a comprehensive overview of conceptions of the international word before discussing international computing and informatics terms. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 18 doi.org/10.35321/bkalba.2020.93.14 nescio), MDS or M.D.S. (Lat. misce, da, signa or misceatur, detur, signetur), thus abbreviations formed from Latin phrases or words (LKRS 1992: 74). Studies of the relationship between abbreviations and words would better show the extent to which an international abbreviation is analogous to an international word, but this question, if we bear in mind R. Marcinkevičienė’s article, has not yet been studied and has merely been raised. When listing sources, SVPR mentions a normative source only after the founding document, another legal act, an indication by a competent authority or an official statement; here, such sources are represented by IATE, the Terminology Bank of the Republic of Lithuania, an encyclopedia, a dictionary, a textbook, and so on (SVPR 2020: 12). Thus, this alone shows that the criteria for translating abbreviations applied in EU institutions do not coincide with the normative criterion established in the VLKK resolution. As becomes clear, the usage under examination should be substantially regulated by a non-linguistic, or metalinguistic, factor, but are no linguistic patterns also emerging in it? This is what will be examined next. 3. SCOPE A total of 214 alphabetic abbreviations—that is, abbreviations formed from the initial letters of the words in a name—were found in 100 legal acts (only non-recurrent abbreviations were counted). Three of them are difficult to assess from the perspective of translation, because the initial letters of the words in the Lithuanian and English names coincide: VIS (Visa Information System and Visa Information System), ESI (European Structural and Investment Funds and European Structural and Investment) and ETSI (European Telecommunications Standards Institute and European Telecommunications Standards Institute). Since abbreviations, as already reviewed, are given in texts after the name, which is translated in any case, there is no way to determine, BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 19 doi.org/10.35321/bkalba.2020.93.14 which name these three abbreviations are based on. Thus, 211 abbreviations will be assessed from the perspective of translation below. The group of two-letter abbreviations does not reveal any clear tendencies. Only two non-Lithuanian ones were found, namely CV (Curriculum Vitae) and SE (European companies), while only 6 Lithuanian ones were found: JT (United Nations), ES (European Union), IT (information technologies), EB (European Community), OL (Official Journal) and, in one legal act, MA (payment volume). All Lithuanian two-letter abbreviations, except the last, are used without the name being given; EB generally forms part of the titles of the legal acts cited, e.g.: they conform to the current rules and procedures of the banking sector and Directive 2004/39/EB. The abbreviation OL (Official Journal) is used in footnotes to indicate the source in which the cited legal acts were published, e.g.: OJ L 25, 2009, 1, 29, p. 28. Judging from SVPR, this small collection of two-letter abbreviations may be the result of an effort to avoid them: translators are instructed that if a phrase consists of only two elements, or can be shortened to two elements, abbreviations are best avoided in Lithuanian documents (SVPR 2020: 10). Long alphabetic abbreviations are also found only sporadically. Among the six-letter non-Lithuanian abbreviations, CEIOPS was found (Committee of European Insurance and Occupational Pensions Supervisors); among the Lithuanian ones, EŽUOGF (European Agricultural Guidance and Guarantee Fund), EŽŪFKP (European Agricultural Fund for Rural Development) and KIPVPS (undertakings for collective investment in transferable securities). The only seven-letter abbreviation is EDPPPIK (Committee of European Insurance and Occupational Pensions Supervisors). The most numerous groups are three- and four-letter abbreviations (see Table 1). The latter does not reveal any clearer pattern: 40 Lithuanian alphabetic abbreviations were found (AIFV, BEPS, BIAS, FPKG, ECBS, EDVF, EIFT, ESĮ, ETPB, EŽKA, PINO, SESV, SVKI, ŽOFI, etc.), BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 20 doi.org/10.35321/bkalba.2020.93.14 non-Lithuanian — 35 (ACER, BBAN, CISE, EEPR, EPER, EIPA, EMAS, EMSA, EPPO, ETSC, EURI, FADO, GATT, GMES etc.)15, including OLAF and CIFE, formed on the basis of French names, which, incidentally, are the only alphabetic abbreviations in the selected sample not formed on the basis of English16. However, the set of three-letter abbreviations reveals a clear predominance of Lithuanian abbreviations: 19 non-Lithuanian three-letter abbreviations were used (BIC, CPA, CPC, GEO, EMA, ISO, SMS, DNR, WAL, WAM etc.), while Lithuanian ones were more than four times as numerous: 79 (AIF, AIS, BKI, BPM, DPS, EEB, EEE, EBI, EIB, EPF, GMO, IRT, MPT, MVI, NCB, OPS, UŽT etc.), making this the largest group of Lithuanian alphabetic abbreviations. TABLE 1. Alphabetic abbreviations by composition Lithuanian | Non-Lithuanian | Total Two-letter | 6 | 2 | 8 Three-letter | 79 | 19 | 98 Four-letter | 40 | 35 | 75 Five-letter | 11 | 14 | 25 Six-letter | 3 | 1 | 4 Seven-letter | 1 | – | 1 Total | 140 | 71 | 211 15Excluding three exceptions, namely the abbreviations EPPB and EASO, EVPRI and ESMA, EDPPI and EIOPA, which are included in both the Lithuanian and non-Lithuanian sets of abbreviations. 16Tools intended for EU text drafters and translators also contain one or another abbreviation of French origin, e.g.: SA (société anonyme), TGV (train à grande vitesse), ASBL (association sans but lucratif). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 21 doi.org/10.35321/bkalba.2020.93.14 Far fewer abbreviations made up of five letters are used, and this sample would suggest that non-Lithuanian ones are more frequent. Fourteen were found: BEREC, CSIRT, GEOSS, ECMWF, ECRIS, EONIA, EIOPA, ETIAS, ICSMS, IOSCO, LIBOR, NARIC, TDAWN, SIENA. Eleven Lithuanian ones were used: BDANP, BKKMN, EDAPP, EFPIS, EJŘŽF, EKSSG, ENADS, EOEVT, EŽŪGF, EDPPI and EVPRI. However, as already noted, there is a tendency to move from EDPPI to EIOPA, and from EVPRI to ESMA, so excluding these abbreviations would further reduce the set of Lithuanian five-letter abbreviations. Nevertheless, these calculations include only abbreviations formed purely alphabetically, i.e. those made up of the first letters of all the words in a name, including several cases usually mentioned separately in discussions of alphabetic abbreviations. For example, The Guidelines on Official Language state that sometimes a word’s beginning may be represented by two letters, and give the examples LST (Lithuanian standard), VšĮ (public institution) (KancKP 1998: 277). Two such abbreviations were found in the sources analyzed: NVO (non-governmental organization) and BPeM (common resolution mechanism). However, works on orthography mention neither among alphabetic nor among syllabic abbreviations those formed by omitting some words of a name, although many such examples occur in the material examined, mostly non-Lithuanian ones: EASA – European Union Aviation Safety Agency, EQAR – European Quality Assurance Register for Higher Education, ECVET – European Credit System for Vocational Education and Training, EQAVET – European Quality Assurance Reference Framework for Vocational Education and Training, LETS – European Law Enforcement Training Scheme, MREL – minimum requirement for own funds and eligible liabilities, TRIPS – Trade-Related Aspects of Intellectual Property etc. Only three Lithuanian abbreviations formed in this way were found: ESS (European system of integrated economic accounts), BLS (Community Generalized Tariff Preferences scheme) and CASS (central repository for reporting and statistical data). The first BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 22 doi.org/10.35321/bkalba.2020.93.14 two were coined following the original—the abbreviations there are likewise composed of three letters, with words of the name omitted. The third also appears to follow the original: it consists of the same number of letters, although translating the name requires more words (cf. CASS – central repository for reporting and statisticsdata repository and CRRS – central repository for reporting and statistics). This raises the question of whether the methods of forming abbreviations are Lithuanian or non-Lithuanian. Perhaps the uncertainty of the answer also contributes to the fact that few such Lithuanian abbreviations occur in the material examined. Apart from the three exceptions already mentioned, the others are reproduced as used in the original, e.g.: The Council’s General Secretariat has also made the authentic documents publicly available in the Public Register of Authentic Travel and Identity Documents Online, known as PRADO. Including such abbreviations in the counts of alphabetic abbreviations would increase the sets of longer non-Lithuanian abbreviations and make them outnumber the Lithuanian ones. However, these will be discussed later; discussion of abbreviations formed in the typical alphabetic manner shows that length alone does not determine the boundary between abbreviations that are translated and those that are not—every length group except seven-letter abbreviations includes abbreviations of both Lithuanian and non-Lithuanian origin, although the former are twice as numerous overall as the latter, 140 and 71 respectively. Nevertheless, the clear predominance of Lithuanian three-letter abbreviations (79 versus 19) is evident, indicating that they are most often translated and prompting an examination of alphabetic abbreviations from other linguistic perspectives. 4. TYPE OF NAME When alphabetic abbreviations are described in sections on orthography, examples are mostly given only of abbreviated proper names, such as UN (United Nations), GD (Grand Duchy of Lithuania BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 23 doi.org/10.35321/bkalba.2020.93.14 Principality) or KAD (Department of National Defence), but among them there are also abbreviations formed from common names, e.g.: UAB – private limited liability company, PVM – value-added tax (LKŽin 1998). It is even stated explicitly that not only proper names but also common names can be abbreviated: “Multiword names, both proper and common, are abbreviated by representing all independent words with their initial capital letters” (LKRS 1992: 73). An examination of the group of alphabetic abbreviations most often translated in EU legal acts—three-letter abbreviations—shows that those formed from common names predominate. Of the 79 Lithuanian ones, 48 are of this kind: AIF – alternative investment funds, AKM – open method of coordination, DFP – multiannual financial programme, DPS – multilateral trading systems, DTD – multiple-identity detector, IUS – institutional protection schemes, MKR – solvency capital requirement, MPV – national central banks for payments, OPS – organised trading systems, PSO – transmission system operators, PSŠ – central counterparties, SUB – owner-occupied dwellings, UŠT – overseas countries and territories, BPeM – Single Resolution Mechanism, etc. One translated abbreviation, EKS, is formed by including proper names—Èltetò-Köves-Szulc paritetai—but the full name is common. A considerable number of Lithuanian abbreviations formed from common names also occur among the four-letter ones: of the 36 Lithuanian abbreviations, 17 are of this kind: AIFV (alternative investment fund managers), BEPS (Common European Asylum System), BIAS (shared environmental information system), BŽŪP (common agricultural policy), CVPD (central securities depositories), GPPB (cash-in-transit companies), KIJT (consolidated tape providers), ŽOFI (fisheries guidance financial instrument), and others. Among the 11 five-letter abbreviations, only two were found: BDANP (biometric data matching service) and BKKMN (common credit BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 24 doi.org/10.35321/bkalba.2020.93.14 cost annual rate). However, this does not mean that four- or five-letter abbreviations formed from common names are not translated. They are also rare among the non-Lithuanian abbreviations. For example, among the 14 five-letter abbreviations, only the following are of this kind: CSIRT (computer security incident response teams), ELTIF (European long-term investment funds), and NARIC (national academic recognition information centres). Among the 35 four-letter abbreviations, only the following are of this kind: BBAN (basic bank account number), IBAN (international bank account number), PEPP (pan-European personal pension product), and—if the principle of translating the name as written is followed—CISE (common information sharing environment), FADO (online system for false and authentic documents), GMES (Global Monitoring for Environment and Security). Thus, four- and five-letter abbreviations formed from common names are used less frequently, and fewer are translated. The smaller number is also reflected in the full sample: of the 211 alphabetic abbreviations, 89 are formed from common names and 120 from proper names (the basis for forming the abbreviations DNS and BGP, used without giving the full name, could not be determined). However, Lithuanian abbreviations clearly predominate among those formed from common names: 71 of the 89 are Lithuanian (see Table 2). There are only 18 non-Lithuanian ones (CV, SE, SCE, BIC, CSIRT, ELTIF, NARIC, PEPP, BBAN, IBAN, etc.), including abbreviations of several system names written in lowercase (FADO, CISE and GMES). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 25 doi.org/10.35321/bkalba.2020.93.14 TABLE 2. Alphabetic abbreviations by type of name Lithuanian Non-Lithuanian Total Formed from a common name 71 18 89 Formed from a proper name 61 59 120 Total 132 77 209 However, the distribution of Lithuanian and non-Lithuanian abbreviations formed from proper names is roughly equal. Three abbreviations in this group, namely EPPB, EVPRI and EDPPI, are used both in Lithuanian and in non-Lithuanian forms (EASO, ESMA and EIOPA), while 61 of the other 117 are of Lithuanian origin: EGA – European Defence Agency, EMT – European Payments Council, EPP – European Search Portal, JPKG – Joint Parliamentary Scrutiny Group, EIVT – European External Action Service, SESV – Treaty on the Functioning of the European Union, EŽŪFKP – European Agricultural Fund for Rural Development, etc. The other 59 are of non-Lithuanian origin, e.g.: GEO – Group on Earth Observations, ISO – International Organization for Standardization, SIS – Schengen Information System, EIPA – European Institute of Public Administration, EMSA – European Maritime Safety Agency, GATT – General Agreement on Tariffs and Trade, ACER – Agency for the Cooperation of Energy Regulators, BEREC – Body of European Regulators for Electronic Communications. This shows that there is the strongest tendency to translate short abbreviations formed from common nouns, but it remains unclear why abbreviations formed from proper names are distributed roughly equally from the point of view of translation. Thus, further analysis is needed. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 26 doi.org/10.35321/bkalba.2020.93.14 5. THE OBJECT DESIGNATED Although the standardizing criterion is oriented toward the prevalence of a name, in 2000 another resolution was adopted by the VLKK, listing six abbreviations for the names of the European Communities and the areas of cooperation among the states that are members of the European Union, namely EB (European Community), EEB (European Economic Community), EAPB (European Coal and Steel Community), BUSP (common foreign and security policy), TVR (justice and home affairs), Euratomas (European Atomic Energy Community); it stated that Lithuanian forms should be used in documents prepared in Lithuanian and in other texts (VLKK 2000). This thematic group is also mentioned elsewhere (Kazlauskienė 2008: 73; Linkevičienė 2013: 28), apparently with the aim of conveying the standardizing position; abbreviations of key documents are also mentioned, such as EŽTK – the European Convention on Human Rights (Linkevičienė 2013: 28). This may suggest that the object designated can matter when choosing a Lithuanian or non-Lithuanian abbreviation. An examination of the groups of letter abbreviations used in translations of EU legislation from this perspective shows that Lithuanian abbreviations formed from common nouns are mostly terms that are widespread in EU legislation or used in a particular legal act—there are 68 such abbreviations: IRT (information and communication technologies), GTV (net asset value), GMO (genetically modified organisms), PMT (fixed tax rates), MVĮ (small and medium-sized enterprises), AKM (open method of coordination), DTM (multilateral interchange fees), MKR (solvency capital requirement), MPT (payment service providers), PPI (institutions for occupational retirement provision), AIFV (alternative investment fund managers), CVPD (central securities BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 27 doi.org/10.35321/bkalba.2020.93.14 depositories), KIPVPS (undertakings for collective investment in transferable securities), etc. In addition to these, three system names are also used as common nouns: AIS (Entry/Exit System), BEPS (Common European Asylum System) and BIAS (Common Information and Analysis System for the Environment). Among the 18 untranslated abbreviations are ones denoting various objects, but the group of code and indicator names stands out somewhat: BBAN, IBAN, BIC, WAL, WAM, LIBOR, EONIA. An examination from this perspective of the group of Lithuanian letter abbreviations formed from proper names reveals that most of them are abbreviations for the names of institutions and organizations, including communities (hereafter collectively referred to as organizations). Of the 61 Lithuanian abbreviations, 47 belong to this thematic group: ES – European Union, EB – European Community, EEB – European Economic Community, EIB – European Investment Bank, EKA – European Space Agency, EPF – European Development Fund, ESF – European Social Fund, ESRV – European Systemic Risk Board, EIVT – European External Action Service, EŽŪFKP – European Agricultural Fund for Rural Development, EŽŪOGF – European Agricultural Guidance and Guarantee Fund, etc. Among the non-Lithuanian abbreviations formed from proper names, abbreviations denoting various kinds of system are prominent—there are nine among the 51 untranslated abbreviations formed from proper names: SIS – Schengen Information System, ECTC – European Credit Transfer System, GEOSS – Global Earth Observation System of Systems, ECRIS – European Criminal Records Information System, SLTD – Interpol’s database of stolen and lost travel documents, ETIAS – European Travel Information and Authorisation System, EMAS – Community eco-management and audit scheme, SIENA – Secure Information Exchange Network Application, EPER – European Pollutant Emission Register. However, some system names (the online system for counterfeit and authentic documents, the global environment and BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 28 doi.org/10.35321/bkalba.2020.93.14 security monitoring system, common European asylum system, market surveillance information and communication system, common information-sharing environment) are written in legislation with lowercase letters; therefore, following the spelling principle, their abbreviations are assigned to the group of abbreviations of common nouns (respectively FADO, GMES, BEPS, ICSMS and CISE). Assigning them to this group would make it larger, and it would grow especially substantially if abbreviations formed by omitting words were included: ECVET (European Credit System for Vocational Education and Training), EQAVET (European Quality Assurance Reference Framework for Vocational Education and Training), TDAWN (Interpol database of travel documents associated with notices), PRADO (Public Register of Authentic Travel and Identity Documents Online), EQAR (European Quality Assurance Register for Higher Education), etc. Nevertheless, an even larger group of non-translated abbreviations consists of abbreviations of organization names—there are 25: ETF – European Training Foundation, ISO – International Organization for Standardization, CEN – European Committee for Standardization, ACER – Agency for the Cooperation of Energy Regulators, CMFB – Committee on Monetary, Financial and Balance of Payments Statistics, CPSS – Committee on Payment and Settlement Systems, OLAF – European Anti-Fraud Office, CIFE – International Centre for European Training, EASA – European Union Aviation Safety Agency, EIPA – European Institute of Public Administration, EPPO – European Public Prosecutor’s Office, ECMWF – European Centre for Medium-Range Weather Forecasts, IOSCO – International Organization of Securities Commissions, CEIOPS – Committee of European Insurance and Occupational Pensions Supervisors, etc. Apart from this thematic group, there are somewhat more abbreviations of the names of documents, programs, and instruments, for example: GATT – General Agreement on Tariffs and Trade, GATS – General Agreement on Trade in Services, TLAC – Total Loss-Absorbing Capacity conditions document, EEPR – European Energy Programme for Recovery, SIENA – Secure Information Exchange Network Application. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 29 doi.org/10.35321/bkalba.2020.93.14 This would suggest that the type of entity named may be important when translating abbreviations: abbreviations of terms are mostly translated, whereas abbreviations of names of systems and instruments tend to be left as used in the original language. However, this factor cannot explain abbreviations of organization names, of which there are many among both Lithuanian and non-Lithuanian forms. Some of those used in the sample of 100 legal acts occur only once, such as ETF, EMA, FATF, ECMWF, which might seem to indicate that the dividing line between them could be drawn according to frequency: names that occur rarely, or abbreviations that are used infrequently, are left as they appear in the original language. Nevertheless, EIPA, EMSA, BEREC, CEIOPS, and OLAF are used frequently in the legal acts; thus, both the names and the abbreviations themselves are widespread, yet these abbreviations are not replaced with Lithuanian ones. Thus, other factors may determine the dividing line within this thematic group of abbreviations. This dividing line is also drawn, incidentally, in the translation tools discussed above. For example, the LV appendix, which provides a list of the main abbreviations, gives Lithuanian forms for the abbreviations BPV (Single Resolution Board), EAA (European Environment Agency), EPSA (European Political Strategy Centre), ESTT (Court of Justice of the European Union), BLES (Belgian-Luxembourg Economic Union), CAVO (Organization of Central American States), EESRK (European Economic and Social Committee), etc., whereas the abbreviations ETC (European Training Foundation), JRC (Joint Research Centre), FRA (European Union Agency for Fundamental Rights), EFSA (European Food Safety Authority), EUSA (European School of Administration), EIGE (European Institute for Gender Equality), EASME (Executive Agency for Small and Medium-sized Enterprises), PARBA (South Asian Association for Regional Cooperation), etc., are non-Lithuanian. The VV list intended for translators does not provide them, but some abbreviations are mentioned in appendices listing organization names, and these suggest that the dividing line is drawn by a finer-grained classification of organizations: abbreviations of international organizations and their highest-level bodies BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 30 doi.org/10.35321/bkalba.2020.93.14 are given here in Lithuanian, for example, JT (United Nations), JTO (United Nations Organization), ŠMT (Nordic Council of Ministers); Lithuanian abbreviations are also provided for the names of EU institutions, for example, EP (European Parliament), ET (Council of Europe)17, whereas non-Lithuanian abbreviations are given alongside the names of structural units, such as European Parliament political groups and committees: ECR (European Conservatives and Reformists Group), IMCO (Committee on the Internal Market and Consumer Protection), etc. (VV 2014: 64–67). Such a dividing line seems to correspond to the normative criterion that abbreviations of names less widespread in Lithuanian may remain untranslated. An even finer-grained classification of institutions and organizations is presented in SVPR, where the criterion of the entity being designated is listed as the sixth criterion (SVPR 2020: 14–24). Unlike VV, it recommends using borrowed abbreviations for the names of international organizations (ASEAN, NAFO, etc.). However, exceptions are made for some abbreviations in this group: the abbreviations of the names of United Nations bodies and certain organizations associated with the United Nations are mentioned as Lithuanian forms (GA, TDO, DIGA, etc.), as are abbreviations of the names of international courts (TTT, TBTBJ, etc.) and organizations in the Baltic Sea region and the Nordic countries (BJVT, BJVSBT, etc.). Other organizations are mentioned in the end, which reveals that they too are treated as exceptions, even though abbreviations of international organizations were identified as borrowed. Thus, although an attempt is made to draw a dividing line among abbreviations of international organizations by classifying these organizations more finely, it is not possible to establish a clear boundary. This is also evident in the discussion of abbreviations of structural-unit names: unlike VV, abbreviations of the names of European Commission Directorates-General and services (JRC, FPI, OLAF, ECFIN, etc.) and of Council configurations (EPSCO, EYCS, etc.) are mentioned here as 17 Names may also be shortened to a single word (European Parliament – Parliament, European Commission – Commission, Council of Ministers of the European Union – Council, etc.) or not shortened at all (VV 2014: 64). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 31 doi.org/10.35321/bkalba.2020.93.14 borrowed. However, the abbreviations of the names of the Council’s preparatory bodies are given in Lithuanian (PPK, EPK, SAK, etc.), and ultimately even those mentioned among the latter are borrowed (SCIFA, CATS, COSI, etc.). If a subgroup is established for the names of decentralized EU bodies, agencies, and joint undertakings, it must likewise be noted that their abbreviations may be Lithuanian (EEA, EGA, etc.) or borrowed (EIGE, EASO, etc.). Thus, when attempting to classify the group of organizations by the entity denoted, one must conclude about almost every subgroup that its abbreviations may be either Lithuanian or non-Lithuanian. Since a non-linguistic factor is mentioned repeatedly when classifying this group (for example, it is said of committee and political-group abbreviations that they should be used in the form approved at the direction of the competent body), it might seem that the exception must be made on account of this factor. However, no such factor is mentioned when distinguishing other groups of denoted entities, yet it is still clear that abbreviations may be Lithuanian or borrowed. For instance, this is stated of each of the two subgroups of document titles: abbreviations of the names of international conventions and agreements, and abbreviations of programs, plans, guidelines, and instruments, may be either Lithuanian (VTK, SPG, DFP, BTL, BSP, etc.) or borrowed (UNCLOS, CITES, ABCP, MASE, etc.). The abbreviations of collections of EU legislation are seemingly given in Lithuanian (KRD, BDAR, etc.), but exceptions are also envisaged (REACH Regulation, CLP Regulation, etc.). Only the groups of system names and terms are more uniform: system names, divided into two subgroups (Information systems, databases and registers and Methodologies, classifiers and indicators), are said generally to use borrowed abbreviations (CARE, GEANT, TRACES, etc.), whereas term abbreviations are said to favor Lithuanian forms (DUK, PDB, IPTR, etc.). This would provide some explanation for why, in actual usage too, term abbreviations are translated, while many system-name abbreviations are not. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 32 doi.org/10.35321/bkalba.2020.93.14 However, most of the other groups distinguished by denoted entity in SVPR include both Lithuanian and borrowed abbreviations. This translator-oriented publication makes clear the importance of the metalinguistic factor, but, as one might infer, it is more significant only for abbreviations of organization names; nonetheless, the abbreviations in almost all the groups it attempts to distinguish vary. When abbreviations are classified on the basis of the denoted entity, it ultimately becomes clear that nearly every group may include both Lithuanian and borrowed abbreviations. This may indicate that other factors are at work in usage itself, drawing a distinction among abbreviations on a different basis. 6. METHOD OF FORMATION SVPR does not mention the method of abbreviation formation among its criteria at all. Examples of both letter-based and syllabic abbreviations are provided for each criterion, without distinction, indicating that the method of formation is not considered important. For example, when the subgroup of names of the commissions of the Committee of the Regions and the European Economic and Social Committee is distinguished according to the denoted-entity criterion, both a letter-based abbreviation CCML and a syllabic one COTER are given as examples (SVPR 2020: 17–18). Or, in distinguishing abbreviations of system names, the examples include not only one formed purely from letters, SITC, and one formed from letters with words omitted, PRADO, but also TRACES (Trade Control and Expert System)—an abbreviation formed by including a syllable (ESRV 2020: 21). It is true that the formation-method factor is also not mentioned in formulating the normative criterion. This is illustrated only with examples of letter-based abbreviations (TO – United Nations Organization, NVS – Commonwealth of Independent States, ES – European Union), and the resolution is also formulated BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 33 doi.org/10.35321/bkalba.2020.93.14 skyrelyje Dėl raidinių santrumpų (VLKK 1997). Nutarimas Dėl raidinių santrumpų buvo priimtas jau 1989 m. (KK 1989), tik vėliau perkeltas (kiek papildžius) į rašybos ir skyrybos taisyklių visumą apimantį 1997 m. nutarimą, o tai rodytų, kad formuluojama nuostata greičiausiai yra radusis iš būtinybės pateikti pačias bendriausias nelietuviškų santrumpų rašymo taisykles, kai lietuvių kalboje rusiškas santrumpas ėmė keisti angliškos santrumpos. Trumpame skyrelyje visi santrumpų vartojimo aspektai negalėjo būti aprėpti, o ir išsamiai santrumpų klasifikacijai nutarime ne vieta. Tačiau rašybos darbuose klasifikacija pagal sudarymo būdą populiari ir reikšminga – ji brėžia ribą tarp santrumpų rašymo ir linksniavimo. Tiesa, rašybos darbuose santrumpos vertimo požiūriu neaptariamos, taigi neaišku, ar ši riba svarbi ir vertimui. The beginnings of classifying abbreviations by method of formation in Lithuanian linguistics probably lie in an article published in the 1964 issue of Kalbos kultūroje, which attempts to provide a classification of all shortened forms used in the language. It focuses mainly on shortening word combinations that function as names, distinguishing four methods and, correspondingly, four results that it proposes to call abbreviations. Two are mentioned as letter-based abbreviations (TSKP, LTSR, VLKJS) and sound-based abbreviations (when pronounced, the sounds merge into a single word: VRES, HES, TASS, nepas (New Economic Policy), FIBA); together, these are proposed to be called initial abbreviations. The other two results concern shortening a compound name to a single word: one is discussed as the result of shortening by taking the beginning of a word and another word (agitpunktas – from agitacinis punktas, profsąjunga – profesinė sąjunga), which are called compound clipped words. The other method and result discussed comprise various cases that do not conform to word-formation rules, in which the beginnings of two words are joined (krikdemas – krikščionis demokratas, partorgas – partinis organizatorius), one of which takes a constituent spanning two syllables (Kominternas – Komunistų Internacionalas, Proletkultas – Proletarinė kultūros-švietimo organizacija) or a stem-spanning BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 34 doi.org/10.35321/bkalba.2020.93.14 constituent (gruporgas – grupės organizatorius, vietkomas – vietos komitetas). All such cases that do not conform to word-formation rules are proposed here to be called syllabic abbreviations. The classification scheme proposed overall is to distinguish compound clipped words from word abbreviations, and then to subdivide the latter into syllabic and initial abbreviations, with the possibility of dividing initial abbreviations into letter-based and sound-based ones. Thus, one scheme attempts to encompass two aspects—the phonetic structure and the method of abbreviation formation. As the examples provided in that article show, most of them are Russian abbreviations that were current at the time. Their foreign origin is also explicitly identified: syllabic abbreviations are described as “words most often formed in other languages and adapted to the grammatical structure of Lithuanian” (Klimavičius 1964: 40), while sound-based abbreviations (TASS, VRES, FIBA) are said to be “taken directly from other languages or translated. Lithuanian does not much favor merging initial sounds into a word; for example, JAV is not pronounced jav. For in Lithuanian, a natural combination, regardless of how convenient the arrangement of vowels and consonants may be for pronunciation, can only have an ending. Hence there is a tendency to read such abbreviations with Lithuanian endings added, as in hesas, Tasas, šecas, vrecas, zillas” (Klimavičius 1964: 41). This suggests that only letter-based abbreviations are considered more characteristic of Lithuanian, while those that resemble words (sound-based and syllabic abbreviations) are regarded as mostly coming from other languages. It also becomes clear that the classification scheme is intended to encompass both Lithuanian abbreviations and those uncharacteristic of Lithuanian, which, under the circumstances in which the Lithuanian language existed at the time, were represented by Russian abbreviations. Later, syllabic abbreviations are indeed distinguished as a category. The section presented in LKRS discusses letter-based abbreviations mainly; after discussing these, however, it notes that there are forms “made up of the first two or three letters, or the first syllables, of each word in the name,” adding that it would be more accurate to call them syllabic abbreviations (LKRS 1992: 74). Although this discussion BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 35 doi.org/10.35321/bkalba.2020.93.14 although it would seem to indicate that syllabic abbreviations are entirely distinguished from alphabetic ones, it is stated that they are usually written with an initial capital and are often declined (Elfa and Kuzbasas); thus, the boundary for both spelling and declension is essentially drawn on the basis of the method of formation. The alphabetic abbreviations under discussion are written here in uppercase, and adding an ending is recommended only for some of them, namely those that can be pronounced by reading the letters as the sounds they represent (TASS-o pranešimas or TASS’o pranešimas), that is, those discussed as phonetic in the 1964 article mentioned above. It is true that the term phonetic abbreviations is not used in LKRS; all abbreviations made up of letters are called alphabetic. Thus, the principal classification emerging from LKRS appears to be that of abbreviations by method of formation. In later works, syllabic abbreviations are clearly distinguished from alphabetic ones, and the basis for this distinction appears to be the method of formation of the abbreviation, along with its different spelling and declension: “Syllabic abbreviations are formed from the first two or three letters of words or from their first syllables. Syllabic abbreviations are often formed from only some of the words in a name. Only the first letter of such abbreviations is capitalized; they often take endings and are declined, e.g., ‘Euratomas’ (European Atomic Energy Community), ‘Eurostatas’ (European Union Statistical Office), ‘Europolas’ (European Police), ‘Unikodas’ (Eng. Unicode)” (Kazlauskienė 2008: 73). However, unlike LKRS, those works also recommend writing syllabic abbreviations in quotation marks, thereby setting them apart from alphabetic ones. A. Kazlauskienė’s article was perhaps the first to propose this idea: “I would suggest that such abbreviations could be recommended for use in quotation marks, since they function in the language as symbolic names” (Kazlauskienė 2008: 73). In other works, the use of quotation marks is already formulated as a rule: “Only the first letter of such abbreviations is capitalized, and the abbreviation itself is written in quotation marks” (Linkevičienė 2013: 29). Incidentally, it is formulated this way in VV, a guide for translators, too: “Syllabic abbreviations are set off by quotation marks BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 36 doi.org/10.35321/bkalba.2020.93.14 (they are equated with symbolic artificial names and written with an initial capital)” (VV 2014: 20). It is true that an exception is made for several abbreviations (Europolas, Interpolas, Eur atomas, Eurojustas and Eurostatas): by tradition, they are written with an initial capital and declined. In general, it is clear that although syllabic abbreviations are distinguished as a type of abbreviation, in terms of spelling they tend to be treated instead as a type of name—symbolic names. Thus, the spelling guides reveal a twofold treatment of syllabic abbreviations: in the spelling mentioned in LKRS, they are regarded more as names with a literal meaning, whereas when written in quotation marks they are regarded more as names with a symbolic meaning. The outcome of addressing the question of translation on the basis of these treatments should differ. Names with a literal meaning are usually translated, while symbolic names are transcribed using the original spelling. It is true that some names with a literal meaning, namely personal and place names, may also be written in the original spelling (VLKK 1997, 2016), but nowhere is it stated that syllabic abbreviations should be equated with place names or personal names. The two examples of syllabic abbreviations given in LKRS, Elfa (electrical factory, electrotechnical factory in Vilnius) and Kuzbasas (Kuznetsk coal basin), do not provide an answer to this question, nor do they clarify whether syllabic abbreviations should be translated: the first example is an abbreviation of Lithuanian origin, while the basis for the formation of the second coincides in Lithuanian and Russian (Kuznetsk coal basin and Кузнецкий угольный бассейн). Incidentally, examples that coincide in two languages are also used to illustrate the discussion of syllabic abbreviations, which is based on abbreviations of English origin. Such is the syllabic abbreviation Euratomas (European Atomic Energy Community and European Atomic Energy Community), included among alphabetic abbreviations in the 2000 VLKK resolution, as well as the commonly cited Eurostatas (European Union Statistical Office and European Statistics), and Europolas (European Police and European Police Office). Such examples also fail to answer the question of phonetic adaptation. It is true that both these examples and the rules as formulated BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 37 doi.org/10.35321/bkalba.2020.93.14 show that syllabic abbreviations should be morphologically adapted, that is, written with Lithuanian endings. Lithuanian symbolic names are not adapted phonetically—they are written in the original spelling (VLKK 1997). The 1997 VLKK resolution would suggest that they should not be adapted morphologically either, that is, they may be written without endings18; however, under a resolution adopted in 2007, only symbolic names following a generic term are to be written without endings (Services provided by “Sonex” Company), while those preceding it are recommended to be declined if they can be fitted into one of the Lithuanian declension paradigms (VLKK 2007). Incidentally, this is also stated in some sources specifically with regard to syllabic abbreviations: “These abbreviations usually take endings and are declined (e.g., ‘Sodra’, ‘Sodros’, ‘Sodrai’); when borrowed from other languages, the required Lithuanian case endings are also added, e.g.: ‘Euratomas’—European Atomic Energy Community; data from ‘Eurostato’ (European Union Statistical Office); transferred to ‘Europoliui’ (European Police); ‘Unikodas’—a standard that defines the encoding in computers of the alphabets of almost all languages and additional symbols, and so on” (Linkevičienė 2014: 29). In any case, even if writing syllabic abbreviations as symbolic names is envisaged, the question of their morphological adaptation remains unclear. In the usage examined, syllabic abbreviations are adapted neither phonetically nor morphologically, except for Europolas, Interpolas, Eur atomas, Eurojustas and Eurostatas—these, as also stated in VV, are written with an initial capital and with endings, for example: Europolas, Eurojustas and the European Border and Coast Guard Agency may each appoint one representative to the SIS II advisory group; 18 “Non-Lithuanian periodical publications, organizations, sports, arts and other collectives, firms, branded products, and other officially used symbolic names in languages using the Latin script (often with numbers or other special references) are written in the original spelling without Lithuanian endings” (VLKK 1997). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 38 doi.org/10.35321/bkalba.2020.93.14 When operational personal data are transferred from Eurojust to Interpol and to States that have appointed Interpol members, this Regulation should apply, in particular its provisions on international data transfers. Other abbreviations are written in capital letters, for example: The Commission concludes an agreement with EUMETSAT on delegation of powers; therefore, the nature of CEDEFOP’s activities should be clearly defined; SOLVIT is an effective out-of-court problem-solving mechanism; ECOICOP should also be aligned with the United Nations’ COICOP — the international standard for classifying individual consumption expenditure by purpose — and therefore ECOICOP should be adapted to align it with the UN COICOP amendments. Even abbreviations such as EUROFOUND, EUROSUR or EURODAC, are written this way, although they are formed like Europol, Eurostat or Eurojust, that is, from the element Euro- and the beginning of another word; for example: since its establishment in 1975, EUROFOUND has played an important role in helping to improve living and working conditions throughout the Union; the Agency should provide the necessary support for the EUROSUR development and use, including the interoperability of systems. It would seem, then, that these short forms are treated as abbreviations rather than as designations with literal or symbolic meanings. However, symbolic names may be written in capital letters, as is also indicated in Part IV of the LV intended for EU legislative drafters. Thus, the use of capital letters may indicate that syllabic abbreviations in EU legal translations are treated as symbolic names. Nevertheless, actual symbolic names are placed in quotation marks here; compare: to implement the service component of the ‘Copernicus’ programme, the Commission may entrust competent bodies, such as the European Environment Agency (EEA), the European Agency for the Management of Operational Cooperation at the External Borders of the Member States of the European Union (FRONTEX), the European Maritime Safety Agency (EMSA) and the European Union Satellite Centre (SATCEN); for this purpose, the Institution should cooperate with the implementers and networks of other relevant Union initiatives, in particular with the European BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 39 doi.org/10.35321/bkalba.2020.93.14 network of public employment services, the Enterprise Europe Network, “Border Focal Point”, SOLVIT and the Senior Labour Inspectors Committee. Only a few instances of syllabic abbreviations written in quotation marks can be found, for example: Europol may also appoint a representative to the VIS, the “Eurodac” and the AIS-ETIAS advisory groups. There may be various reasons why syllabic abbreviations tend not to be written as symbolic names. As discussed, there is uncertainty about the applicable norms. Moreover, in texts in the formal administrative style, where the aim is to convey official names as accurately as possible, adaptation could be perceived as distorting the official name (Vaskelaitė 2011: 72). Some cases suggest that context may also play a role, that is, the surrounding letter abbreviations, for example: This Regulation, together with Regulation (EU) 2019/818 of the European Parliament and of the Council (34), establishes a framework ensuring the interoperability of the Entry/Exit System (hereinafter ‘AIS’), the Visa Information System (hereinafter ‘VIS’), the European Travel Information and Authorisation System (hereinafter ‘ETIAS’), EURODAC, the Schengen Information System (hereinafter ‘SIS’) and the European Criminal Records Information System for third-country nationals (hereinafter ‘ECRIS-TCN’). Since the texts are translations, the source text probably also has an influence—such forms are often written in capital letters in English-language legislation too, for example: EUROSUR is necessary; In addition, the Commission should also rely on the European Organisation for the Exploitation of Meteorological Satellites (EUMETSAT) for the operation of dedicated missions in accordance with its expertise and mandate. And if they are not written in capitals, they are not set off by quotation marks either, for example: Eurofound should also take account of the medium- and long-term perspectives in that context; The ESP should also be established to support the objectives of the EES, VIS, ETIAS, Eurodac, SIS, ECRIS-TCN and Europol data. Moreover, in the text, abbreviations written both in capital letters and otherwise are used as abbreviations—that is, the full name is given first and the abbreviation in parentheses, for example: The HICP and the harmonised index of consumer prices at constant BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 40 doi.org/10.35321/bkalba.2020.93.14 tax rates (HICP-CT) should be broken down into categories of the European classification of individual consumption according to purpose (ECOICOP). They continue to be used as letter abbreviations, standing for the full name: The ECOICOP should also be consistent with the UN COICOP, which is the international standard for classifying individual consumption according to purpose; therefore, the ECOICOP should be adapted to align it with changes to the UN COICOP. When the full name is given, there is no need to explain the abbreviation further, and thus no explanatory words are used, although these are usually needed when such abbreviations appear in untranslated texts (Vaskelaitė 2011); this also prevents the abbreviations from standing out as symbolic names. Moreover, this presentation generally makes the connection between the abbreviation and its full name, which is literal in meaning, apparent; for example: CEDEFOP (French Centre européen pour le développement de la formation professionnelle), ECOFIN (Economic and Financial Affairs), EUMETSAT (European Organisation for the Exploitation of Meteorological Satellites).It is true that there are also forms in which only one syllable connects the abbreviation to the name, such as SOLVIT (Market Problem Solving Network) or RAPEX (Rapid Alert System for dangerous non-food products), but the strong tendency in the original to provide the full name also makes their connection with the full name apparent. Thus, these formations too are not written as symbolic names, even though their connection to a longer name is more symbolic; and, as may be inferred from the SVPR, that symbolism is perceived. Indeed, symbolic meaning is cited in the SVPR as the fourth criterion: “A borrowed abbreviation is chosen if, in the original language, it was deliberately formed to give the abbreviation symbolic meaning, which would be lost in translation” (SVPR 2020: 13). Nevertheless, the SVPR does not recommend placing in quotation marks even these abbreviations, which have little in common with their longer names. In view of the method of formation, a distinction should be drawn in texts between abbreviations formed in different ways; and in spelling references, the spelling prescribed for syllabic abbreviations is, moreover, the same for all syllabic abbreviations. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 41 doi.org/10.35321/bkalba.2020.93.14 All syllabic abbreviations, with the exception of a few already mentioned, are written in the same way in the material under examination; the only choice is to write them in capital letters rather than in quotation marks, which would suggest that they are treated more as abbreviations than as symbolic names. The rule for writing syllabic abbreviations set out in the LKRS also appears not to favour writing these formations, although the spelling of the original might in some cases seem to encourage it. In addition to the reasons already mentioned, the difficulties may stem from uncertainties in language standardisation related to phonetic adaptation. Moreover, the LKRS states that syllabic abbreviations are only most often written with an initial capital and are only most often declined. This publication is more oriented towards general usage, so the possibility of translating abbreviations into proper nouns, as evidenced by the spellings Elfa, Kuzbasas, may be formulated there with general-use texts in mind rather than specialised usage. In addition, in the original, which may have a direct or indirect effect on the translated texts, names formed by this shortening method are written with an initial capital only in some cases; in other cases they are written in capital letters and thus treated as abbreviations. Yet even in those other cases, capital letters are used in the Lithuanian texts, cf.: Inspire should be based on the infrastructures for spatial information and INSPIRE should be based on spatial information infrastructures established by the Member States; As the three tripartite agencies, namely Eurofound, the European Agency for Safety and Health at Work (EU OSHA) and the European Centre for the Development of Vocational Training (Cedefop), address issues <...> close coordination among them is required) and since the three tripartite agencies, namely EUROFOUND, the European Agency for Safety and Health at Work (hereinafter ES-OSHA) and the European Centre for the Development of Vocational Training (hereinafter CEDEFOP), address <...> issues, close coordination among them is required. This may, of course, indicate an effort to make the spelling of one or another abbreviation uniform BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 42 doi.org/10.35321/bkalba.2020.93.14 but at the same time, the tendency to use the spelling conventions for alphabetic abbreviations would suggest a tendency not to distinguish syllabic abbreviations from alphabetic ones. However, it would be difficult to distinguish them on the basis of English abbreviations. There are many whose formation involves only one syllable or a few initial letters, but which are otherwise made up of letters, such as ECOICOP (European classification of individual consumption according to purpose), ESSPROS (European system of integrated social protection statistics), COSME (Competitiveness of Enterprises and small and medium-sized enterprises), EURES (European network of employment services), CEPOL (Collège Européen de Police), and so such abbreviations do not conform to the description of syllabic abbreviations found in Lithuanian spelling works—that they are formations consisting only of a few initial letters or syllables. There are abbreviations formed by adding just one extra letter, such as ENISA (European Union Agency for Network and Information Security). As already shown in the discussion of alphabetic abbreviations, many abbreviations consisting solely of letters are also used, though they are not formed in the manner mentioned in Lithuanian spelling works—from the initial letters of each word—for example, PRADO (Public Register of Authentic Travel and Identity Documents Online). Furthermore, as noted in this section, there are abbreviations formed by taking just one syllable from a word in a name. Thus, it would be difficult to draw among English abbreviations the distinction that Lithuanian spelling works draw on the basis of formation method. In the usage under examination, no such distinction is made either—in terms of spelling or translation. All such abbreviations are written in the same way and are not translated, including those formed from initial letters while omitting words in the name. The sample under examination brings to light perhaps the sole abbreviation NAFTAP (financial intermediation services indirectly measured), which was not copied from BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 43 doi.org/10.35321/bkalba.2020.93.14 the original, but formed from a Lithuanian name, though possibly following the original19. The uniform treatment of abbreviations formed in different ways in translations of EU legislation would suggest that, even if the concept of a syllabic abbreviation is applied, a syllabic abbreviation is more likely considered to be one that can be divided into syllables or pronounced as a syllable, rather than one formed from syllables. In an article on acronyms, R. Marcinkevičienė notes a different nature of English abbreviations: when forming them, letter combinations are selected so that they are easy to pronounce; consequently, the earlier practice of taking only independent words, only their initial letters, and only their natural order is often not followed (ADLA – Danish Association for Applied Linguistics)20. Furthermore, in an effort to create an easily readable letter combination, attempts are made to devise the name itself so that, when shortened, it yields a word already present in the language and having a meaning, for example, Speech and Language Technology – SALT (Marcinkevičienė 2003: 92). It would follow that, for English abbreviations, the relevant criterion is not the method of abbreviation formation but the phonetic structure, explained in that article as the aim of achieving wordlikeness. Such a criterion, however, would draw a different dividing line among abbreviations from the one generally drawn in Lithuanian spelling works through the distinction between alphabetic and syllabic abbreviations. The following section will examine whether this criterion matters when translating abbreviations in EU legislation. 19 It is difficult to determine the actual method of formation, since the abbreviation FISIM may have been formed either from initial letters (financial intermediation services indirectly measured) or by including the first two letters of one word (financial intermediation services indirectly measured). 20 On this basis, the author distinguishes old, or strict, acronyms from new, or free, acronyms (Marcinkevičienė 2003: 92). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 44 doi.org/10.35321/bkalba.2020.93.14 7. PHONETIC STRUCTURE It might seem that the phonetic-structure criterion is not important when translating three-letter abbreviations. For example, the large group of Lithuanian abbreviations includes both those that can be pronounced as a syllable or a short word (EGA, EKA, EPI, EBI, EIF, EKS, NAC, SUB, TAB, TAS, AIF, AIS), and those that do not form a syllable or a combination of syllables (AGS, AKM, BKI, EEB, EAA, ECB, EPF, EPP, EŽF, IIP, MVI, NKI, NRI, NVO, PPI, PPO, SVA, TDO, UŠT, UPF), or are made up entirely of consonants (BNP, BPM, BVP, DFP, DPS, DTD, DTM, FST, KRS, GTV, MKR, MPT, NCB, PGP, PGS, PRF, PSŠ, PVB, TDS, TVF, TVR). The same applies to abbreviations of non-Lithuanian origin, cf. CEN, GEO, IPA, SIS, WAL, WAM, ISO and CPC, DNS, BGP, SMS, SPC, DNR, DFI, ETF. However, among four-letter abbreviations, those that can clearly be read as a word predominate. Most of these are non-Lithuanian: EIPA, EASA, EIPA, EMSA, ESMA, SEPA, EMAS, EURI, FADO, NACE, NATO, CIFE, CISE, NATO, EPPO, EASO, EURI, OLAF, ACER, EPER, IFAC, ITER, IBAN. Others can be read as a monosyllabic word: GATS, GATT, LETS, GMES, FATF, TLAC, PEPP, SLIM. Such abbreviations are also the most numerous among five-letter ones: BEREC, GEOSS, ECRIS, EONIA, LIBOR, ELTIF, ETIAS, IOSCO, NARIC, SIENA, EIOPA. The same is true of the six-letter CEIOPS. However, abbreviations that can be pronounced as a syllable or a combination of syllables are also found among those translated. These include the four-letter BEPS, BIAS, AIFV, EBPO, ESBO, EIVT, EŽKA, ELPA ESIL, ŽOFI, PINO, EFPIS, NMAC, TAST, PATM, SESV. Comparing them with the abbreviations in the original shows that when a combination that is easier or similarly easy to pronounce occurs in Lithuanian, there is a tendency to translate the abbreviation, e.g.: BEPS (cf. CEAS), BIAS (cf. SEIS), AIFV (cf. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 45 doi.org/10.35321/bkalba.2020.93.14 AIFM, EŽKA (plg. EFKA), ELPA (plg. EFTA), ESIL (plg. ESIS), ŽOFI (plg. FIG), PINO (plg. WIPO, EFPIS (plg. ESFS), NMAC (plg. CNACs), TAST (plg. IASB). Penk आप? There are few five-letter Lithuanian abbreviations formed by the typical letter-based method, but ENADS, ESAPP, EFPIS, EŽŪGF, EOEVT can also be pronounced as words. Such data show that the criterion of sound structure is important. This is also demonstrated by EVPR, a resource intended for EU translators, which mentions sound structure as a criterion for choosing an abbreviation: a borrowed abbreviation may be chosen if the Lithuanian abbreviation is long, complex, and difficult to pronounce (SVPR 2020: 13). Admittedly, this criterion is mentioned only as the sixth, but the classification of abbreviations by the object they denote presented in the same publication shows that among borrowed abbreviations are usually those that can be pronounced as a syllable or combination of syllables, whereas Lithuanian abbreviations generally cannot be pronounced in this way and are often consonantal. For example, in the subgroup of names of international organizations, the borrowed abbreviations listed are PIF, ASEAN, NAFO, ICES; in the subgroup of Council configurations, COMPET, EPSCO, EYCS, ECOFIN; in the subgroup of Council preparatory bodies, EUMS, CATS, SCIFA, COSI; in the subgroup of Council working parties, DROIPEN, COASI, COMET; in the subgroup of decentralized EU bodies, EIGE, EASO, SATCEN, BEREC; and in the group of system names, CARE, GEANT, TRACES, PRADO, SITC, NACE classifier, EURIX, among others (EVPR 2020: 13–24). The abbreviations TTT, TGS, PPK, EPK, EFK, PSK, TBTR, BJVT, DPPK, BJVSBT, EESRK, EJ RŽF, among others, are listed as Lithuanian. The English abbreviations given alongside them (respectively ICJ, GSC, TPC, EPC, EFC, PSC, ICTY, CBSS, BSSSC, KLDR, EESC, ESKK, EMFF) show that they do not form an easily pronounceable sequence of sounds. It would appear that there is a tendency to translate abbreviations that do not form an easily pronounceable sequence of sounds in the original, while refraining from breaking up such a sequence when one is formed. Moreover, this is also anticipated by another criterion (the third) specified in SVPR—that of recognizability: “A borrowed abbreviation may be BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 46 doi.org/10.35321/bkalba.2020.93.14 pasirenkama, jei ją išvertus į lietuvių kalbą gali pasunkėti komunikacija“ (SVPR 2020: 12). Tiesa, ji suformulavus užsienama apie tam tikras specializuotas sritis, logotipus, prekių ženklus, ir tai rodytų, kad veikiausiai turimos omenyje būtent tų sričių santrumpos. However, analysis of actual usage has shown that all abbreviations deliberately coined to resemble words also remain untranslated: EASA, ESCO, EQAR, EMAS, ECVET, EQAVET, PRADO, TEMPO, SIENA, INSPIRE, CEPOL, SATCEN, SOLVIT, INTCEN, COSME, ESSPROS, RAPEX, and others. They can all the more readily be pronounced as words or syllables, since this resemblance is intentional. This would suggest that, in terms of translation, the dividing line between abbreviations is drawn not by how they are formed, but by their sound structure. And judging from the 100 legal acts, this criterion is probably the most prominent. Few exceptions to this tendency were found. For instance, five four-letter abbreviations made up of consonants in English were left untranslated: CMFB (Committee on Monetary, Financial and Balance of Payments Statistics), CPSS (Committee on Payment and Settlement Systems), ECTC (European Credit Transfer System), SLTD (Interpol’s Stolen and Lost Travel Documents Database), and IPPC (Integrated Pollution Prevention and Control). However, among five-letter abbreviations, only ICSMS (Information and Communication System for Market Surveillance) and ECMWF (European Centre for Medium-Range Weather Forecasts) were left in the original language. Such exceptions may be determined by other factors, such as source or prevalence criteria; the latter, under the SVPR, allows a foreign-language abbreviation that is widespread in several languages to be used. The criterion concerning the object denoted may also have an influence: abbreviations denoting the same object are intended to be treated uniformly with regard to translation. On the other hand, the criterion that emerges naturally from usage, focusing on sound structure, may explain why the attempt to prescribe uniform abbreviations for groups of objects denoted has not been successful. After all, actual abbreviation usage also reveals that names of various objects can be abbreviated to resemble words BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 47 doi.org/10.35321/bkalba.2020.93.14 — abbreviations for organizations (EIPA — European Institute of Public Administration, BEREC — Body of European Regulators for Electronic Communications), systems or networks (GEOSS — Global Earth Observation System of Systems, ECRIS — European Criminal Records Information System), documents, programmes or instruments (GATS — General Agreement on Trade in Services, SIENA — Secure Information Exchange Network Application, EURI — European Union Recovery Instrument), numbers, codes, indicators (IBAN — international bank account number, EURIBOR — euro interbank offered rate), and so on. Conversely, abbreviations for all these objects may also be coined without seeking a resemblance to a syllable or word, e.g.: CPSS — Committee on Payment and Settlement Systems, ECTS — European Credit Transfer System, SLTD — Interpol’s Stolen and Lost Travel Documents Database, EFSDF — Common Loss Absorption Capacity Terms Document. It is true that word-like names are commonly coined artificially for systems, which would explain why many of the longer foreign-language abbreviations, or those formed from letters other than the initial letters of a name, designate systems. However, even in English there is no attempt to make shortened terms resemble words, which would explain why abbreviations of terms constitute the majority of Lithuanian abbreviations. As the discussion of abbreviation classification has shown, the sound-structure aspect is also reflected in Lithuanian orthographic works. The LKRS does not classify abbreviations in this respect, distinguishing only between alphabetic and syllabic abbreviations; however, in its discussion of alphabetic abbreviations, it envisages different ways of pronouncing them: some are read by pronouncing each letter separately, while others are pronounced by blending the sounds, that is, as a syllable or word (TASS, FIAT, NATO, ELTA). Their capacity for inflection is also envisaged as varying: those pronounced by blending sounds may be declined (TASS-o or TASS’o report), while those with a feminine ending are even prescribed to be written with an initial capital only (Elta), that is, as BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 48 doi.org/10.35321/bkalba.2020.93.14 pavadinimą (LKRS 1992: 74). Tai rodytų šių santrumpų artimumą skiemeninėms santrumpoms21, o kartu rodytų, kad garsinės sandaros kriterijus tarp santrumpų brėžia kitą ribą, nei ji čia pat brėžiama pagal sudarymo būdą: panašumo į žodį neturinčios santrumpos (skaitomos raid iškai) ir labiau žodinės santrumpos, apimančios skaitomas suliejant garsus raidines santrumpas ir skiemenines santrumpas. O vienas klasifikacijos ištakas paaiškinantis straipsnis, rašytas anuometinėmis lietuvių kalbos gyvavimo aplinkybėmis, rodytų, kad pastaruosius du pogrupius sieja dar ir nelietuviška kilmė, arba nebūdingumas lietuvių kalbai. Discussion of abbreviations in the present circumstances of language use (Marcinkevičienė 2003; Kazlauskienė 2008; Vaskelaitė 2011, 2020) shows that alphabetic abbreviations that can be read by blending sounds, such as SEPA, OPEC, EONIA, have already become commonplace, while syllabic abbreviations, illustrated with Russian examples and considered atypical of Lithuanian, remain relevant despite changes in the circumstances of language use, and may even have become more relevant (cf. the single loanword example given in the LKRS, Kuzbasas, and examples usually given in 21st-century works: Eurostat, Europol, Unikodas, Euratom, ECOFIN, TARGET, BUCOM, and others). As such abbreviations have spread, as may be inferred from R. Marcinkevičienė’s 2003 article, which, drawing mainly on foreign-language abbreviations and a foreign-language understanding of them, proposed treating all abbreviations pronounceable as words uniformly, the sound-structure aspect should become more relevant than the way abbreviations are formed. The usage examined, which is directly connected with foreign-language abbreviations, shows that it is indeed becoming relevant—although it is formulated 21 In later works, there is a tendency to do away with this exception: in A. Kazlauskienė’s article, alphabetic abbreviations formed in this way are proposed to be written like other alphabetic abbreviations, for example, BAFTA-os (Kazlauskienė 2008: 73), while another work mentions this spelling as the standard form (Linkevičienė 2013: 29). BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 49 doi.org/10.35321/bkalba.2020.93.14 various criteria regulating this usage, nevertheless, from the perspective of translation, the line between abbreviations is drawn primarily on the basis of sound structure. Of course, the usage examined concerns written language, so what should matter is not the ease of pronouncing an abbreviation, but the fact that such abbreviations, being word-like, perform a naming and individualizing function, just like proper nouns (cf. Jakaitienė 2010: 264)—they make it possible to distinguish objects of the same type from one another. CONCLUSIONS Although recent works on Lithuanian spelling have sought to draw the boundary between abbreviations chiefly on the basis of their structure, an examination of their translation tendencies suggests that the boundary is probably drawn on the basis of phonological structure, which determines whether an abbreviation resembles a word. The usage examined is directly related to English abbreviations, for which this aspect is particularly relevant; however, albeit indirectly, it also reflects the discussion of abbreviations presented in Lithuanian spelling chapters: although abbreviations are distinguished by structure (and spelling and inflectional possibilities) as alphabetic and syllabic, shared spelling and inflectional possibilities are envisaged for abbreviations that can be pronounced by blending sounds and thus resemble words, and for syllabic abbreviations. It is worth noting that one article written in an earlier period also indicates that the latter abbreviations are mostly of foreign origin. It also appears that the classification of abbreviations presented in Lithuanian spelling chapters was probably determined by the aim of covering both Lithuanian abbreviations and abbreviations of non-Lithuanian origin used in Lithuanian. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 50 doi.org/10.35321/bkalba.2020.93.14 However, abbreviations are not classified or discussed in spelling chapters in terms of origin, and therefore no criterion for translating non-Lithuanian abbreviations is formulated there either. The criterion formulated in the VLKK resolution, which has normative force, is oriented toward the currency of the abbreviated name, covers only alphabetic abbreviations, is not intended for translated texts, and is sufficiently clear. In the absence of clarity, and with the use of abbreviations having expanded considerably, usage develops its own criteria. Applying the normative criterion formulated to the usage examined is also difficult because of its specific nature: these are legal acts whose drafting is regulated and coordinated, and is regulated not at the level of Lithuania but in a multilingual environment. Usage functioning under such conditions reveals that the use of abbreviations is governed not only by linguistic factors but also by institutional ones. However, as shown by a work that summarizes abbreviation practices in EU institutions and provides recommendations for translators, linguistic criteria are also sought and efforts are made to reconcile them. Nevertheless, the most prominent criterion to emerge from usage itself—that is, from translations of legal acts into Lithuanian—is the phonological structure of an abbreviation, which determines whether it resembles a word: from the perspective of translation, abbreviations that can be pronounced as one-syllable or multisyllabic words tend to be treated alike and distinguished from abbreviations that do not permit such pronunciation. This criterion is relevant to English, where so-called acronyms tend to be formed to create a pronounceable sequence of sounds, whether meaningless or constituting a real word. Such abbreviations are relevant to written language because, by resembling words, they perform a naming and individualizing function like proper nouns, making it possible to distinguish objects of the same type. At the same time, however, they also have full-form equivalents, that is, they are used as abbreviations of longer names. Since those equivalents are always given in the original being translated, and it is apparent from them BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 51 doi.org/10.35321/bkalba.2020.93.14 that there is a link between the abbreviated name and the abbreviation, in translations of EU legal acts abbreviations that have little connection with the full name are not generally distinguished from alphabetic abbreviations on the basis of spelling. In other words, all abbreviations are treated alike in terms of spelling. This may be influenced by this feature of the original, as well as by normative uncertainties or other factors; however, an important reason may also be the criterion brought to light by translation: as phonological structure (word-likeness) emerges as the most important criterion, drawing a boundary between abbreviations in Lithuanian spelling works on the basis of the criterion of formation becomes inadequate. SOURCES122 Regulations of the European Central Bank (EC) No 1745/2003 (EC) No 2548/2000 (EU) 2017/1539 (EU) 2020/2004 Directives of the European Parliament and of the Council (EU) 2015/2366 2006/123/EC (EU) 2019/879 2006/43/EC 2001/29/EC 2007/2/EC 2004/48/EC 2009/65/EC 22 EU legal acts are cited in abbreviated form. The year appearing before or after the hyphen indicates the date of adoption of the legal act. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 2011/61/EU 2014/17/EU 2014/65/EU (EC) 2516/2000 (EC) No 1082/2006 (EC) No 1161/2005 (EC) No 1221/2002 (EC) No 1221/2009 (EC) No 1445/2007 (EC) No 451/2008 (EC) No 924/2009 (EU) 2015/2219 (EU) 2016/1037 (EU) 2016/2135 (EU) 2016/792 (EU) 2016/794 (ES) 2016/942 (ES) 2017/1131 (ES) 2017/1601 (ES) 2018/1727 (ES) 2018/1860 (ES) 2018/1971 (ES) 2019/1024 (ES) 2019/1156 (ES) 2019/1238 (ES) 2019/127 (ES) 2019/128 (ES) 2019/1896 (ES) 2019/515 (ES) 2019/816 (ES) 2019/817 (ES) 2019/881 (ES) 2020/1041 (ES) 2020/1043 (ES) 2020/1503 (ES) 2020/2092 (ES) 2020/2220 (ES) 2020/2221 (ES) 2020/2222 (ES) 2020/2224 (ES) 2020/493 (ES) 2020/558 (ES) 2020/698 (ES) 2020/852 (ES) 2020/873 (ES) Nr. 1052/2013 (ES) Nr. 1092/2010 (ES) Nr. 1094/2010 BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 53 doi.org/10.35321/bkalba.2020.93.14 (EU) No 1173/2011 (EU) No 1233/2011 (EU) No 1287/2013 (EU) No 1288/2013 (EU) No 1304/2013 (EU) No 2015/760 (EU) No 236/2012 (EU) No 260/2012 (EU) No 331/2014 (EU) No 377/2014 Commission Regulations (EB) Nr. 1889/2002 (EB) Nr. 264/2000 (EB) Nr. 27/2004 (EB) Nr. 498/2007 (ES) 2020/1434 (ES) 2020/2008 (ES) 2020/2097 (ES) Nr. 220/2010 (EB) 10/2008 (ES) Nr. 472/2013 (ES) Nr. 603/2013 (ES) Nr. 604/2013 (ES) Nr. 806/2014 (ES) Nr. 909/2014 (ES) Nr. 912/2010 (EU) No 978/2012 (EU, Euratom) No 883/2013 2009/138/EC Council directives 2001/115/EC 2008/9/EC (EC) No 2012/2002 (EC) No 479/2009 (EC) No 58/2003 (EU) 2020/521 (EU) 2020/672 (EU) 2020/699 (EU) No 1024/2013 (EU) No 407/2010 (EU, Euratom) 2020/2093 (EC) No 2182/2004 BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 LITERATŪRA DUK 2020: Dažnai užduodami klausimai apie IATE. 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Prieiga internete: http://www.vlkk.lt/vlkk-nutarimai. VLKK 2007: Valstybinės lietuvių kalbos komisijos nutarimas „Dėl simbolinių pavadinimų linksniavimo“ (2007 m. balandžio 5 d., Nr. N-1(110). Prieiga internete: http://www.vlkk.lt/vlkk-nutarimai. BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 56 doi.org/10.35321/bkalba.2020.93.14 VLKK 2016: Protokolinis nutarimas dėl rekomendacijos „Dėl autentiškų asmenvardžių gramatinimo“ (2016 m. gegužės 26 d., Nr. Pn-3). Prieiga internete: http://www.vlkk.lt/vlkk-nutarimai/protokoliniai-nutarimai/rekomendacija-del-autentisku-asmenvardziu-gramatinimo. VV – Europos Sąjungos institucijų vertimo į lietuvių kalbą vadovas. Prieiga internete: https://ec.europa.eu/info/sites/info/files/about_the_european_commission/what_the_european_commission_does/documents/interinstitutional_translation_guide_lt.pdf [žiūrėta 2020 12 20]. Zemlevičiūtė Palmira 2018: Kitų kalbų poveikis lietuviškai informatikos ir kompiuterijos terminijai. – Albina Auksoriūtė, Jolanta Gaivenytė-Butler, Solvita Labanauskienė, Asta Mitkevičienė, Robertas Stunžinas, Alvydas Umbrasas, Palmira Zemlevičiūtė. Lietuviškos informatikos ir kompiuterijos terminijos tyrimai, 150–307. Gauta 2020 11 20 Priimta 2020 12 28 BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 57 doi.org/10.35321/bkalba.2020.93.14 TRANSLATION OF ABBREVIATIONS IN EU LEGISLATION: CRITERION ISSUE Summary Abbreviations in the normative linguistic work are considered as an orthography level object, therefore they are discussed in orthography sections. However, this discussion alone makes it clear that it is difficult to restrict it to the level of an orthography – the structure of abbreviations, origin, relationship with names and other issues are dealt with as well. The purpose of the orthography sections in their turn is to provide orthographic rules, so these questions are just touched instead of being analyzed in a more detailed manner. Moreover, they are not dealt with in the works focused on other linguistic levels. The recent use of abbreviations is extremely abundant, including non–Lithuanian abbreviations, the peculiarities of which in their formation, declension and orthography coincide with the mentioned sections of the Lithuanian language orthography only partially, leads to various uncertainties in use. The article analyzes one of the uncertainties: the issue of translation of abbreviations and acronyms. As the texts of administrative style, namely translations of EU legal acts (directives and regulations) were selected for the analysis, attention is focused on the translation criteria, i.e. seeks to find out what leads in a translation to the selection of a Lithuanian or non–Lithuanian abbreviation. In this respect, two types of abbreviations are considered in the works of the Lithuanian language orthography: Abbreviations (acronyms) formed from the first letters of the words of the name (EU, ECB, OECD) and abbreviations formed by several first letters or syllables of a name (Eurostat, Eurodac, Interpol). It becomes clear that various factors may influence BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351–7204 RAMUNĖ VASKELAITĖ. Santrumpų vertimas Europos Sąjungos teisės aktuose: kriterijaus klausimas | 58 doi.org/10.35321/bkalba.2020.93.14 whether the abbreviations are to be translated, but the criterion of a similarity to a word or a name plays a significant role, i.e. the abbreviations with such similarity, even if they are composed solely of letters, are tend to be left in the same way as they were used in the original language. Thus, from the point of view of translation, the boundary drawn between the abbreviations does not coincide with the boundary that is drawn between them in the Lithuanian language orthography works based on their structure. There is also a lack of conformity with the other limits provided in orthography works, such as based on orthography, inflection, relation to symbolic names. The article pays less of attention to such aspects while giving focus on the translation criteria, but they arise as problematic and unsolved issues in a normative attitude. KEYWORDS: acronym, syllabic abbreviation, proper names, generic names, symbolic names. RAMUNĖ VASKELAITĖ Lietuvių kalbos institutas Petro Vileišio g. 5, LT-10308 Vilnius [email protected] BENDRINĖ KALBA 93 (2020) http://journals.lki.lt/bendrinekalba ISSN 2351-7204