EU Low Voltage Directive exclusion triage workflow

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 clarifies that the rating check is based on input or output voltage, not voltages that may appear only inside the equipment.

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 a product should not be removed from LVD scope just because another label feels more familiar.

Route the product out of the LVD only when the product facts match one of the listed exclusions. Keep the exclusion wording, the matching facts, and the alternate regime or rationale in the evidence file.

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 just to be cautious. Radio equipment within the RED is not subject to the LVD as a separate directive, even though RED Article 3 uses LVD-type safety objectives without the LVD voltage limit. Machinery with an electrical supply must meet electrical safety objectives, but the machinery declaration route is governed by Machinery legislation rather than an LVD declaration.

Close the triage with a short record that a reviewer can test against the product. The record should not just say 'excluded' or 'LVD applies'; it should show the facts that caused that result and identify the EU product law used for any alternate route.

If the LVD applies, the file 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.