Applicability TestEU

EU Low Voltage Directive Applicability Test

Test whether a product is electrical equipment designed for use with 50-1000 V AC or 75-1500 V DC input or output ratings, then check the Annex II exclusions before treating it as an LVD product.

Use this page to document a scope conclusion for battery-powered products with chargers, standalone components, evaluation kits, radio equipment, EMC-only issues, machinery overlap, and market-surveillance evidence.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
9

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

The Low Voltage Directive applicability question starts with the product's rated electrical input or output, not with every internal voltage that may appear inside the equipment. A product is in the LVD lane when it is electrical equipment made available on the Union market, is designed for use in the LVD voltage bands, is not excluded by Annex II, and is not fully dealt with by a more specific product regime for the same safety question.

Section 1

1. Confirm the product and voltage rating

Record the exact product model, intended EU supply route, and whether the item is supplied for distribution, consumption, or use on the Union market. The LVD scope test then asks whether the electrical equipment is designed for use with a voltage rating between 50 and 1000 V AC or between 75 and 1500 V DC.

Use the rated input or rated output voltage. The Commission LVD guide explains that equipment with either rated input or rated output inside the band is treated as within scope, and that internal higher voltages do not drive the scope answer by themselves. Directive 2014/35/EU has applied through Member State transposing laws since 20 April 2016.

  • In scope candidate: mains power supply unit, appliance, lighting equipment, switchgear, electric motor, cable, appliance coupler, cord set, or similar equipment with rated input or output in the LVD bands.
  • Out of this LVD test: equipment whose rated input and output are only below 50 V AC and 75 V DC, or whose highest rating exceeds 1000 V AC or 1500 V DC. Assess an accompanying charger or integrated power supply separately when its own rating falls within the LVD bands.
  • Multiple ratings: treat the product as an LVD candidate when the highest rated input or output falls inside 50-1000 V AC or 75-1500 V DC.
Section 2

2. Apply Annex II before assigning the LVD route

Annex II is a hard exclusion screen. If the product is one of the listed equipment categories or the issue is the listed radio-electrical interference phenomenon, do not force the product into the LVD route merely because a voltage rating falls in the band.

The Commission guide describes the Annex II list as exhaustive for equipment explicitly excluded from the LVD. Keep the exclusion basis narrow: the fact that one part of a product resembles an excluded item does not automatically remove the full assembled product from the LVD.

  • Exclude electrical equipment for explosive atmospheres, radiology and medical purposes, electrical parts for goods and passenger lifts, electricity meters, domestic plugs and socket outlets, electric fence controllers, radio-electrical interference, qualifying ship/aircraft/railway equipment, and qualifying custom-built professional R&D evaluation kits.
  • Domestic plugs and socket outlets are excluded, but special plugs and socket outlets such as appliance couplers or industrial-purpose connectors are not excluded on that basis.
  • A custom-built evaluation kit needs all of the exclusion facts: built for specific customer or joint R&D requirements, uniquely suited to that project, destined for professionals, used solely at R&D facilities, and not later supplied as a regular product.
Section 3

3. Resolve components, kits, and battery-powered products

Do not treat every electrical part as a standalone LVD product. Basic components whose safety can only be assessed after integration into final equipment are not covered as such by the LVD and should not be CE-marked under the LVD unless another Union act requires CE marking.

Other components can still be LVD products when their own safety risk can be assessed before integration. The LVD guide gives transformers and electric motors as examples of incorporated components that are covered as such and must be CE-marked when the LVD applies.

  • Basic-component edge case: integrated circuits, transistors, diodes, capacitors, resistors, relays for printed circuit boards, and similar parts normally need an integration-based safety assessment rather than a standalone LVD conclusion.
  • Covered-component edge case: transformers, electric motors, lamps, starters, fuses, switches for household and similar fixed electrical installations, appliance couplers, cord sets, and cable management systems should not be treated as excluded merely because they are components.
  • Battery-powered edge case: a low-voltage battery device may sit outside LVD because its supply rating is below the bands, while its accompanying charger or integrated power supply can be inside the LVD scope.
Section 4

4. Check CE route and overlapping EU product rules

When the LVD applies, the conformity route is internal production control: the manufacturer establishes technical documentation, assesses risks, ensures manufacturing control, affixes CE marking to compliant equipment, and draws up the EU declaration of conformity. The LVD does not require a notified body for the manufacturer's LVD conformity assessment.

Adjacent EU regimes can change the route or split the work. EMC covers electromagnetic compatibility rather than LVD safety objectives. Radio equipment is not subject to the LVD as a separate directive, but RED Article 3(1)(a) imports the LVD safety objectives with no voltage limit. Machinery and other product legislation may cover mechanical or product-specific hazards while LVD remains relevant only for electrical safety aspects that are not displaced by a more specific rule.

  • CE trigger: do not affix CE marking for the LVD until the product satisfies the applicable LVD requirements and the technical documentation and EU declaration are ready.
  • EMC split: use EMC for electromagnetic disturbance and immunity questions; use LVD for electrical safety objectives within its scope.
  • RED split: for radio equipment, test safety through RED Article 3(1)(a), which uses LVD safety objectives without applying the LVD voltage limits as a standalone LVD route.
  • Market surveillance readiness: keep the LVD scope note, Annex II analysis, standards list, risk assessment, test reports, technical file, EU declaration, labels, instructions, and responsible economic-operator details available for authority requests.
Recommended next step

Check an LVD scope call before release

Review voltage ratings, Annex II exclusions, components, chargers, standards, CE marking evidence, and adjacent EU product-law obligations before a product is placed on the EU market.

Section 5

Applicability record to keep

The useful output is a short product-specific record that separates facts from conclusions: product identity, rated input and output, market-placement role, Annex II screen, component or kit analysis, battery or charger treatment, applicable CE legislation, and any unresolved assumptions.

Attach the records that let another reviewer reproduce the conclusion: nameplate or datasheet voltage ratings, bill of materials for relevant electrical parts, charger and power-supply specifications, standards mapping, test reports, risk assessment, drawings, instructions, labels, EU declaration draft or final version, and any decision that RED, EMC, Machinery, or market surveillance rules require separate treatment.

State the basis for each conclusion. Directive 2014/35/EU and the Member State laws that transpose it are binding; the Commission LVD Guide is non-binding guidance. If product facts do not fit a guide example cleanly, record the uncertainty instead of treating the example as a legal classification.

  • Use one conclusion per product model or electrical configuration; do not reuse a conclusion after a material component, power-supply, firmware, intended-use, supplier, or market change without checking the facts again.
  • When relying on an Annex II exclusion, name the exact exclusion and keep the facts that make it fit, especially for domestic socket outlets and custom-built R&D evaluation kits.
  • When the product is outside LVD, state the adjacent regime that still needs attention, such as RED for radio equipment, EMC for disturbance questions, Machinery for machinery hazards, or market surveillance obligations for Union harmonisation products.
  • End with one explicit outcome: LVD applies and an Annex III file is required; Annex II excludes the product or phenomenon and another identified route must be checked; the rated voltage is outside LVD and any charger or power supply is assessed separately; or facts remain unresolved and EU placement is held pending a documented decision.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Supports general EU product-law concepts used in the record, including economic operators, conformity assessment, CE marking, and market surveillance.
"implementing EU product rules"
eur-lex.europa.eu
Referenced sections
  • Lists the equipment and phenomena outside the scope of the Low Voltage Directive.
"EQUIPMENT AND PHENOMENA OUTSIDE THE SCOPE"
eur-lex.europa.eu
Referenced sections
  • Supports the technical documentation contents used in the applicability record, including design information, standards, risk assessment, and test reports.
"adequate analysis and assessment of the risk"
eur-lex.europa.eu
Referenced sections
  • Supports the RED rule that radio equipment is not subject to the LVD except through RED safety requirements, which apply LVD safety objectives with no voltage limit.
"with no voltage limit applying"
single-market-economy.ec.europa.eu
Referenced sections
  • Supports the Commission statement that the manufacturer alone is responsible for LVD conformity assessment and that CE marking follows testing and the applicable conformity assessment procedure.
"manufacturer alone is responsible"
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