LVD FAQ Components

Sometimes. The Commission LVD Guide says the directive's scope generally includes electrical equipment intended for incorporation into other equipment as well as equipment used directly. Member States have applied the recast Directive's substantive provisions since 20 April 2016. An item does not leave LVD scope merely because it will be built into a larger product.

The important exception is for basic components whose safety depends, to a very large extent, on how they are integrated into the final product and for which a risk assessment cannot be undertaken on the component alone. The guide gives examples such as active electronic components, passive components, and some electromechanical components. Those basic components are not covered as such by the LVD and should not carry CE marking for the LVD unless another applicable Union law requires CE marking.

By contrast, other electrical components intended for incorporation can be covered as LVD equipment when their own risk assessment can be made. The guide names transformers and electrical motors as examples, while noting that safety aspects of incorporation into the final product normally still need further assessment.

A finished-product manufacturer cannot outsource the final LVD assessment to component certificates. Component evidence is useful input, but the final technical documentation must still show how the complete electrical equipment meets the LVD safety objectives in its design, manufacture, and operation.

For covered electrical components, keep supplier declarations, standards information, test reports, ratings, installation limits, and traceability data with the product technical file. For basic components, keep the data sheets, ratings, safety limits, mounting or spacing assumptions, and integration checks that show why the finished design remains safe.

The LVD technical documentation should include a general equipment description, drawings and schemes of components, sub-assemblies and circuits, explanations needed to understand those drawings and operation, standards or other technical specifications used, design calculations or examinations, and test reports. The risk assessment should match the actual finished product, including risks that a harmonised standard may not cover.

For LVD-covered electrical equipment, the manufacturer uses internal production control, draws up technical documentation, issues the EU declaration of conformity, and affixes CE marking to each individual item that satisfies the applicable requirements. The LVD Guide also states that the LVD CE marking is not followed by a notified body's identification number because Module A does not require notified body involvement in the production phase.

For basic components outside LVD scope as such, do not create a false LVD CE-marked component record. Instead, keep the integration evidence inside the finished-product technical documentation and make the final product's declaration and CE marking cover the final equipment when the LVD applies.

Importers and distributors should check the correct boundary too. For electrical equipment placed on the EU market, importers must ensure the manufacturer has drawn up technical documentation, the equipment bears CE marking, and the required documents accompany it. Distributors must verify CE marking, required documents, instructions, and safety information before making equipment available.

The practical record should answer two questions: what is the component's own LVD status, and how was it made safe in the final equipment? A concise evidence pack is better than a generic component compliance folder that does not connect to the final design.

For each safety-relevant component, link the bill of materials entry to the drawing or circuit, the rating or standard relied on, the supplier evidence, the installation or assembly constraint, the finished-product hazard assessment, and any verification result. This helps show that the equipment and its component parts can be safely and properly assembled and connected, which is one of the LVD safety objectives.

Avoid unsupported shortcuts. Do not claim every component needs its own LVD CE mark, do not claim no component can ever be LVD equipment, and do not cite national penalty details unless an official source for the Member State at issue supports them.