ApplicabilityEU

EU Low Voltage Directive (LVD) 2014/35/EU Applicability Test

Decide if the product is in scope or excluded with audit-grade reasoning.

Use this to create a reusable scope memo per product family covering voltage limits, Annex II exclusions, component status, and overlap with other CE regimes.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

An LVD applicability decision is only as good as the product facts behind it. This page turns the directive, the 2018 LVD Guide, and the Blue Guide into a practical scope test so you can document voltage limits, exclusions, component treatment, online sales exposure, and the economic operator role that carries the CE evidence burden.

Section 1

Before you start: capture the minimum product facts

If you do not have these facts, you are guessing, and scope guesses cause expensive redesign and retesting later.

Output: a one page scope memo and an initial applicable legislation list that engineering, compliance, and the commercial owner all use.

  • Rated voltage, AC or DC, frequency, mains connection method, external power supply strategy, and power class.
  • Intended use environment, user type, foreseeable misuse, installation conditions, and duty cycle.
  • Product form: finished equipment, sub assembly, component, kit, or spare part; variants and accessories included in the offer.
  • Sales model: Union manufacturer, importer, authorised representative, distributor, fulfilment service provider, and whether EU targeted online sales are in scope.
Section 2

Step 1 - Are you within the LVD voltage limits?

The LVD covers electrical equipment designed for use at 50 to 1000 V for alternating current and 75 to 1500 V for direct current. Start with the rated input of the product you actually place on the market, not only the internal rails after conversion.

Borderline trap: if you market a mains powered external power supply and a low voltage device together or separately, each item may need its own scope conclusion and evidence path.

  • Confirm rated input voltage and capture the exact power architecture from mains to downstream electronics.
  • Record whether the product is a finished electrical item, or only a basic component whose safety can only be assessed once incorporated.
  • If you sell the power supply, charger, or control panel separately, decide its LVD status separately.
Section 3

Step 2 - Explicitly test every Annex II exclusion

The fastest scope failure is forgetting that Annex II excludes specific product categories even when they are electrical.

The LVD Guide also clarifies that many basic components are not electrical equipment for LVD purposes, while some standalone electrical subassemblies such as transformers or electric motors can be.

  • Check and record exclusions for equipment intended for use in an explosive atmosphere, radiology and medical electrical equipment, electrical parts for goods and passenger lifts, electricity meters, domestic plugs and socket outlets, electric fence controllers, and radio electrical interference products.
  • Check whether the product is a custom built evaluation kit for professionals used solely at research and development facilities.
  • If the item is a basic component such as a semiconductor, resistor, or connector, document why it is not itself electrical equipment; if it is a transformer, motor, or similar standalone item, test whether it is independently in scope.
Section 4

Step 3 - Is another Union regime also relevant?

Multi directive products are normal. LVD often sits beside EMC and may sit beside RED, RoHS, or machinery rules depending on product type and features.

Use the Blue Guide approach: decide whether you have one finished product under several acts, or whether another regime governs the same safety issue for that product type.

  • If the product includes radio functions such as Wi-Fi or Bluetooth, test RED scope as well as LVD and EMC.
  • If the product is machinery, a lift related item, or another product governed by a more specific regime, document which act governs electrical risk conformity assessment.
  • If the product is offered online into the EU, treat EU targeted listings as making the product available on the Union market.
Section 5

Step 4 - Who is the manufacturer for compliance purposes?

Scope is not only about the product. It is also about which economic operator must hold the technical file, sign the DoC, and cooperate with market surveillance authorities.

Article 10 matters here: an importer or distributor becomes the manufacturer if it markets the product under its own name or modifies the product in a way that can affect conformity.

  • Manufacturer duties: design and manufacture to Annex I, carry out Module A, draw up technical documentation, sign the DoC, affix CE marking, and keep the file for 10 years.
  • Importer duties: place only compliant equipment on the market, keep a copy of the DoC for 10 years, and ensure technical documentation can be obtained on request.
  • Online and distance sales: identify the EU based economic operator that performs Article 4 tasks under Regulation (EU) 2019/1020 where required.
Section 6

Step 5 - If in scope, create the next three artifacts immediately

Once scope is confirmed, stop debating and start building the evidence chain. Delay here usually means the release gate fails late and expensively.

Use the linked pages to turn the scope outcome into engineering work, documentation, and post market readiness.

  • Annex I safety objective mapping with hazards, controls, standards clauses, and tests.
  • Conformity assessment plan covering Module A, DoC ownership, CE marking, traceability, and instruction language requirements.
  • Annex III technical documentation index with risk analysis, drawings, standards register, test reports, and a response pack export.
Recommended next step

Turn EU Low Voltage Directive (LVD) 2014/35/EU Applicability Test into an operational assessment

Assessment Autopilot can take EU Low Voltage Directive (LVD) 2014/35/EU Applicability Test from deciding whether these obligations apply in practice to a reusable workflow inside Sorena. Teams working on EU Low Voltage Directive (LVD) 2014/35/EU can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Primary sources

References and citations

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