EU Low Voltage Directive conformity assessment and CE marking

Annex III Module A requires the manufacturer to establish technical documentation, control manufacturing, affix the CE marking to compliant equipment, and draw up a written EU declaration of conformity for the product model. No LVD conformity-assessment procedure requires a notified body. A manufacturer may use laboratory reports or voluntary certificates as evidence, but those documents are not an LVD approval and do not replace the manufacturer's assessment or declaration.

The record should connect the exact product model to the applicable LVD safety objectives, the design and manufacturing evidence, the standards or technical solutions used, the test reports or examinations relied on, and the production controls that keep later units consistent with the assessed design.

The manufacturer performs the LVD assessment. Before placing equipment on the market, an importer must check that the manufacturer completed the appropriate procedure, prepared the technical documentation, affixed CE marking, supplied the required documents, and met the identification and contact-detail duties. Before making equipment available, a distributor must check CE marking, required documents, instructions and safety information in the required Member State language, and the manufacturer and importer identification details. If either actor has reason to believe the equipment is non-compliant, it must not proceed until conformity is restored. An importer or distributor that markets equipment under its own name or trademark, or modifies it in a way that may affect compliance, assumes the manufacturer's LVD obligations.

Harmonised standards are useful because Article 12 gives a presumption of conformity for the safety objectives covered by references published in the Official Journal of the European Union (OJEU). That presumption is limited to the standard, parts of the standard, and objectives actually covered; it does not remove the need to assess product-specific risks.

When a harmonised standard is applied only in part, Annex III requires the technical documentation to identify the parts used. When no relevant harmonised standard is used, the record must describe the other technical solutions selected to meet the LVD safety objectives. The Directive also contains narrower presumptions based on International Electrotechnical Commission (IEC) safety provisions published through Article 13 and, if neither harmonised nor qualifying international standards are available, certain national standards under Article 14; neither route turns a private certificate into regulatory approval.

The EU declaration of conformity is the manufacturer's legal statement that the LVD safety objectives have been demonstrated. Article 15 requires the declaration to follow the Annex IV model structure, include the Module A elements, remain continuously updated, and be translated into the language required where the product is placed or made available.

CE marking follows the conformity assessment. Article 17 requires the CE marking to be visible, legible, and indelible on the equipment or data plate; if that is not possible or warranted because of the nature of the equipment, it must be placed on the packaging and accompanying documents. The marking must be affixed before the equipment is placed on the market. Under the LVD, there is no notified-body identification number beside the CE mark because the Directive does not require notified-body intervention.

Many LVD products also fall under other Union harmonisation legislation. The LVD expressly allows a single EU declaration of conformity where more than one Union act requires a declaration, but the combined declaration must still identify every applicable act and its publication references.

Keep the combined CE file separated by obligation: LVD safety objectives and electrical hazards belong in the LVD assessment; electromagnetic compatibility (EMC), radio, Restriction of Hazardous Substances (RoHS), machinery, construction-products, or other requirements need their own applicability basis and evidence where they apply. The CE mark represents conformity with all applicable CE-marking legislation, not only the LVD. Radio equipment within Directive 2014/53/EU is excluded from the LVD as a separate product category, although the Radio Equipment Directive applies LVD safety objectives without the LVD voltage limit.