EU Low Voltage Directive FAQ

Directive 2014/35/EU applies to electrical equipment designed for use with a voltage rating between 50 and 1000 V for alternating current, or between 75 and 1500 V for direct current, except for equipment and phenomena listed in Annex II.

The Commission LVD guidance explains that the voltage rating is the input or output rating, not voltages that may appear inside the equipment. For products with multiple input or output ratings, the product is treated as within scope as soon as the highest rating falls within the LVD bands.

The Directive has applied through Member State implementing laws since 20 April 2016. The Commission's August 2018 LVD Guide explains the scope questions below, but the Directive and the national laws that transpose it are legally binding.

Annex II excludes a closed list: 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, certain specialised equipment for ships, aircraft, or railways, and custom-built professional evaluation kits used only in research and development facilities.

The Commission guidance says the Annex II list is exhaustive for equipment explicitly excluded from LVD scope. Domestic plugs and socket outlets are excluded, but special plugs and socket outlets for appliance couplers or industrial purposes are not excluded on that basis.

Battery-operated equipment with ratings below the LVD voltage bands is outside the LVD on that voltage basis. The accompanying battery charger, external power supply, or integrated power supply unit can still be within LVD scope when its input or output rating is within the LVD bands.

The Commission LVD guidance gives practical adapter examples: simple travel adapters made only from plug and socket elements are not covered by the LVD, while multiple travel adapters with switches, sliding contacts, USB charging, overvoltage protection, overload protection, LEDs, or other covered elements are treated as LVD products.

Some components are covered and some are not. The Commission LVD guidance says the LVD generally includes electrical equipment intended to be incorporated into other equipment, but basic components whose safety can only be assessed after incorporation are not treated as LVD products on their own.

Basic electronic components such as integrated circuits, transistors, diodes, resistors, filters, and similar parts are examples of components outside the LVD as standalone products. Components such as transformers and electric motors can be covered as LVD electrical equipment when their own safety can be assessed before incorporation.

The manufacturer is responsible for designing and manufacturing the electrical equipment in accordance with the LVD safety objectives, drawing up technical documentation, carrying out the Annex III conformity assessment, issuing the EU declaration of conformity, and affixing the CE marking.

Importers must place only compliant electrical equipment on the EU market. Before placing the product on the market, they must check that the manufacturer carried out conformity assessment, prepared technical documentation, applied CE marking, supplied required documents, and met identification obligations. Distributors must act with due care and verify CE marking, required documents, instructions, safety information, and manufacturer/importer identification before making equipment available.

Placing on the market means the first commercial supply of the equipment in the EU; making available covers any commercial supply for distribution, consumption, or use, whether paid or free. An authorised representative may perform only the tasks in its written mandate. The manufacturer cannot transfer the duty to design and manufacture compliant equipment or the duty to draw up technical documentation.

For a private-label product, the name on the offer, product, declaration, and packaging must match the assigned role. An importer or distributor that sells equipment under its own name or trademark, or modifies it in a way that may affect compliance, takes the manufacturer obligations. Warehousing, marketplace listing, and order fulfilment do not by themselves settle the LVD role; follow who first supplies the product in the EU, who owns or controls the offer, whose name is used, and whether the product was changed.

For online sales, decide whether the offer targets EU end users and retain the offer date, product identifier, seller identity, delivery territory, manufacturer/importer details, Article 4 operator where required, displayed safety information, and the unit or batch supplied. A fulfilment service provider can be the Article 4 operator where the statutory conditions apply, but that does not replace any LVD manufacturer, importer, or distributor duties arising from the supply chain.

Manufacturers must identify the equipment with a type, batch, serial number, or other identifying element. They must provide their name, registered trade name or trademark, and postal contact address on the equipment, or on packaging or an accompanying document where equipment size or nature prevents marking the equipment itself.

The equipment must be accompanied by instructions and safety information in a language easily understood by consumers and other end-users in the Member State where the equipment is made available. Annex III technical documentation must support conformity assessment with a product description, drawings and schemes, explanations, applied standards or other technical solutions, design calculation or examination results, and test reports.

Harmonised standards are voluntary, but Article 12 gives presumption of conformity for equipment that conforms to harmonised standards, or parts of them, whose references have been published in the Official Journal of the European Union and that cover the relevant LVD safety objectives.

Teams must check the current OJEU publication and withdrawal status for each standard they rely on. Commission Implementing Decision (EU) 2023/2723 publishes LVD harmonised-standard references in one act and includes withdrawal tables, and later implementing decisions can amend those references, restrictions, and withdrawal dates.

The CE marking can be affixed only after the applicable conformity assessment has shown that the equipment satisfies the LVD requirements. Under the LVD, conformity assessment is internal production control under Annex III; the manufacturer ensures and declares conformity on its sole responsibility.

The Commission LVD page states that the new LVD does not require notified bodies to assess products before placement on the market. Voluntary certificates can support supplier or test evidence, but they do not replace the manufacturer's conformity assessment, EU declaration, or CE marking obligations.

Manufacturers, importers, and distributors have continuing obligations after placement or making available. If they consider or have reason to believe equipment is not in conformity, they must take corrective measures to bring it into conformity, withdraw it, or recall it where appropriate. Where the equipment presents a risk, they must inform competent national authorities in the Member States where it was made available.

Market surveillance authorities may evaluate equipment that presents a risk, require corrective action, require withdrawal or recall, and notify the Commission and other Member States where non-compliance is not limited to one country. Formal non-compliance can also be based on missing or incorrect CE marking, EU declaration, technical documentation, or manufacturer/importer contact information.