WorkflowEU

EU Low Voltage Directive exclusion triage workflow

Use LVD to decide whether an electrical product is inside the voltage scope, outside under Annex II, or better routed to radio equipment, EMC, Machinery, or another EU product regime.

The workflow records the product facts, voltage ratings, exclusion basis, component or kit treatment, boundary legislation, and evidence needed before release.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Overview

Directive 2014/35/EU has applied since 20 April 2016. LVD starts with the product's rated input and output voltages, then checks the exact Annex II exclusions, component treatment, and product-law boundaries. Run it before EU release and again after a change to ratings, intended use, radio or moving function, integration, supplied accessories, or exclusion facts. The result names the accountable actor and concludes that LVD applies, a named exclusion applies, the item is not covered as LVD equipment in its own right, another EU product law carries the conformity route, or release remains blocked.

Section 1

Voltage scope and first product facts

Start with the electrical equipment as it will be made available on the EU market. Record the model, intended use, user population, rated input voltage, rated output voltage, power supply arrangement, accessories supplied with it, and whether the item is a finished product, component, evaluation kit, machinery, or radio equipment.

The LVD applies to electrical equipment designed for use with a voltage rating between 50 and 1000 V AC or between 75 and 1500 V DC, unless an Annex II exclusion applies. The LVD Guide bases the check on rated input or output, not voltages appearing only inside the equipment. For multiple input or output ratings, it applies the highest-rating rule; a lower selectable mode must not be used to keep equipment whose highest rating exceeds the upper limit inside LVD scope.

  • Trigger: new EU release, rating or power-architecture change, new variant, supplied-accessory change, or mismatch among rating records.
  • Actor: the manufacturer product owner gathers facts, electrical engineering confirms declared AC/DC input and output, and product regulatory approves the voltage result.
  • Action: list every declared input and output by mode, identify the highest applicable rating under the Commission guide, disregard internal-only voltages for Article 1 scope, and assess a charger, external supply, dock, or integrated supply separately.
  • Branch: below 50 V AC and 75 V DC means outside the LVD voltage band on that fact pattern; within 50-1000 V AC or 75-1500 V DC proceeds to Annex II; exceeding 1000 V AC or 1500 V DC is outside LVD voltage scope; inconsistent or incomplete ratings remain unresolved.
  • Records: datasheet, controlled electrical specification, rating artwork, power architecture, accessory list, intended use, variant matrix, reviewer, date, assumptions, and change trigger.
  • Outcome: voltage-in-scope and proceed; voltage-outside-low; voltage-outside-high; separate supply assessment required; or release blocked pending named evidence.
Recommended next step

Review LVD exclusion decisions before release

Use the triage result to decide whether to open an LVD technical file, route the product to RED, EMC, Machinery, ATEX, lifts, medical, transport, or another EU regime, or retain a documented Annex II exclusion.

Section 2

Annex II exclusions to check before opening an LVD file

If the product is inside the voltage band, check Annex II before assigning an LVD conformity path. Annex II is a closed list of equipment and phenomena outside the LVD scope, so similarity to an excluded product is not enough.

Route the product out of the LVD only when its facts match the wording and conditions of a listed exclusion. Record the alternate legal route separately. Exclusion from the LVD does not by itself mean that no EU product law applies or that the product must not bear CE marking under another applicable act.

  • Trigger: a voltage-in-scope result or a product description suggesting an Annex II equipment category or phenomenon.
  • Actor: the product regulatory lead owns the legal match; engineering and the relevant ATEX, medical, lifts, transport, EMC, or R&D specialist verify the technical facts.
  • Action: test every Annex II category, cite its exact wording, and record why the facts meet or fail it; distinguish domestic plugs and socket outlets from appliance couplers or industrial products, and split radio-electrical interference from product-wide electrical safety.
  • Branch: explosive-atmosphere equipment routes to ATEX; the medical, lift, meter, domestic plug or socket, and electric-fence categories route by exact facts; ship, aircraft, or railway equipment qualifies only with the required international-body safety provisions and compliance evidence.
  • Branch: an evaluation kit qualifies only if custom-built for a specific customer or joint project, uniquely suited to that project, destined for professionals, and used solely at an R&D facility; regular provision, catalogue availability, or general laboratory use defeats that basis.
  • Records: exclusion matrix, specification and photos, intended-use and project documents, alternate-law analysis, transport safety provision, EMC split, reviewer, approval date, and reassessment trigger.
  • Outcome: named Annex II exclusion with alternate route; no exclusion and continue LVD; radio-interference routed to EMC while product safety continues; or release blocked.
Section 3

Components, kits, radio equipment, EMC, and Machinery boundaries

For components, ask whether the item's safety can be assessed on its own. The Commission LVD Guide treats basic components whose safety depends heavily on final integration as outside LVD scope as such, while components such as transformers and electric motors can be LVD equipment when their own risk assessment can be performed.

For boundary products, do not duplicate declarations merely as a precaution. Radio equipment within the RED is not subject to the LVD as a separate directive, even though RED Article 3 applies health and safety requirements corresponding to the LVD objectives without the LVD voltage limit. Until Regulation (EU) 2023/1230 applies on 20 January 2027, the machinery boundary is governed by Directive 2006/42/EC; electrical hazards of machinery within that regime follow its conformity route rather than a separate LVD declaration.

  • Trigger: the item is incorporated into other equipment, sold as a development item, has intentional radio, is wired telecom equipment, has moving parts, or raises electromagnetic-disturbance questions.
  • Actor: the product regulatory lead coordinates component engineering, radio and EMC review, and machinery safety; the manufacturer approves the route.
  • Action: determine whether a component permits a stand-alone risk assessment; classify radio, wired telecom, machinery, and EMC from the finished product's functions and intended use rather than choosing a convenient declaration.
  • Branch: an integrated circuit, resistor, capacitor, PCB connector, PCB relay, or similar integration-dependent item is a not covered as LVD equipment as such; a transformer, motor, appliance coupler, cord set, switchgear item, lighting product, or power supply that can be independently risk-assessed continues as LVD equipment when its ratings fit.
  • Branch: radio equipment routes to RED without a separate LVD declaration, while RED safety applies without the LVD voltage limit; wired non-radio telecom equipment continues LVD triage; EMC handles disturbance while LVD handles safety where applicable.
  • Branch: for machinery, record the placement date and controlling law; through 19 January 2027 apply the Machinery Directive boundary, and from 20 January 2027 assess the Machinery Regulation route.
  • Records: integration drawing and risk rationale, intended use, instructions and advertising, radio interfaces, machinery classification, EMC/LVD split, declaration strategy, applicable date, reviewer, and open issues.
  • Outcome: LVD component in its own right; not covered as such; RED route; LVD wired-equipment route; machinery route; combined LVD and EMC route; or escalation required.
Section 4

Evidence retained from an exclusion decision

Close the triage with a short record that a reviewer can test against the product. Show the facts behind an 'excluded' or 'LVD applies' result and identify the EU product law used for any alternate route.

If the LVD applies, the record should move into Article 6 and Annex III evidence: technical documentation, risk analysis and assessment, applicable standards or other technical solutions, test reports, EU declaration, CE marking, and production-control evidence. If the LVD does not apply, keep enough evidence to explain why the LVD declaration and CE marking route was not used for that product.

  • Trigger: a branch result is ready for approval, an assumption remains open, or a design, supplier, rating, accessory, intended-use, standards, market, or authority event may change it.
  • Actor: the product regulatory owner assembles the record, engineering signs the technical facts, and the manufacturer release authority accepts, blocks, or returns the decision.
  • Action: connect the conclusion to the exact model and configuration, cite the controlling source, resolve contradictory records, name the alternate law, and create a change-control link; if LVD applies, open the Article 6 and Annex III work.
  • Branch: LVD applies and moves to risk analysis, standards or technical solutions, tests, internal production control, declaration, CE marking, instructions, and traceability; an exclusion or alternate-law route closes only when its conditions and evidence are complete.
  • Records: rating evidence, accessory supplies, Annex II matrix, component or kit analysis, RED/EMC/machinery/ATEX/lifts/medical/transport routing, source URLs, owner, approver, date, assumptions, and re-check triggers.
  • Outcome: approved LVD route; approved named exclusion; approved basic-component treatment; approved alternate-law route; conditional decision with owner and due date; or release blocked.
Primary sources

References and citations

eur-lex.europa.eu3 citations
Referenced sections
  • General EU product-law guidance used for product classification, economic operator roles, technical documentation, and evidence practices.
  • General EU product-law guidance for classifying products, identifying economic operator roles, and keeping technical documentation tied to applicable Union harmonisation legislation.
  • Supports retaining classification, technical documentation, standards, and risk-assessment evidence in a way market-surveillance reviewers can inspect.
"specific Union harmonisation legislation"
More quoted passages
"The manufacturer needs to document the assessment"
eur-lex.europa.eu2 citations
Referenced sections
  • Primary source for routing electromagnetic compatibility and radio-electrical interference issues outside the LVD safety analysis.
  • Grounds the route for radio-electrical interference and EMC phenomena that are not handled as LVD safety objectives.
"electromagnetic compatibility"
eur-lex.europa.eu2 citations
Referenced sections
  • Primary legal source for LVD voltage scope, Annex II exclusions, manufacturer obligations, technical documentation, EU declaration, and CE marking.
  • Primary legal source for the LVD voltage range and the link between market access, safety objectives, technical documentation, EU declaration, and CE marking.
"electrical equipment designed for use within certain voltage limits"
More quoted passages
"between 50 and 1 000 V for alternating current"
eur-lex.europa.eu2 citations
Referenced sections
  • Primary source for routing radio equipment to RED instead of treating it as separately subject to the LVD.
  • Primary source for routing radio equipment to RED rather than treating it as independently subject to the LVD.
"Radio equipment falling within the scope of this Directive"
single-market-economy.ec.europa.eu2 citations
Referenced sections
  • Commission LVD page used for the public policy context and official LVD topic page URL.
  • Commission LVD page used to ground the page's treatment of LVD as the EU product-safety regime for electrical equipment within defined voltage limits.
"Low Voltage Directive"
eur-lex.europa.eu
Referenced sections
  • Primary legal source for the exact categories of equipment and phenomena outside LVD scope.
"EQUIPMENT AND PHENOMENA OUTSIDE THE SCOPE"
eur-lex.europa.eu
Referenced sections
  • Primary legal source for LVD technical documentation, risk analysis and assessment, technical specifications, and test-report evidence where the LVD applies.
"technical documentation shall include an adequate analysis"
eur-lex.europa.eu
Referenced sections
  • Supports the 20 January 2027 application date and the transition from Directive 2006/42/EC to the Machinery Regulation.
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