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Treat the spare part as an LVD product in its own right when it is electrical equipment supplied for the EU market, falls within the 50-1000 V AC or 75-1500 V DC range, is not excluded from the Directive, and can be assessed for safety as supplied. The LVD Guide gives transformers and electrical motors as examples of components intended for incorporation that can be covered as such by the LVD.

Do not put a CE mark on a basic component merely because it will later sit inside electrical equipment. The LVD Guide distinguishes basic components, whose safety can only largely be assessed after incorporation, from other electrical components for which a risk assessment can be made before incorporation.

For a part built into finished electrical equipment, the finished-product file should show both the part's suitability and the safety of the assembled result. Annex I of the LVD requires electrical equipment and its component parts to be made so they can be safely and properly assembled and connected, and it also requires protection against hazards when the equipment is used as intended and adequately maintained.

This is why a repair bill of materials is not enough. The record should show that the replacement part has the same or acceptable ratings, insulation, thermal limits, mechanical fit, environmental limits, installation instructions, and safety warnings for the equipment in which it is used.

The original equipment manufacturer remains responsible for the LVD compliance of equipment it places on the market under its name. A company that imports an LVD-covered spare part from outside the EU must check that the manufacturer completed the conformity assessment, prepared technical documentation, applied CE marking, and supplied required documents before the part is placed on the EU market.

An importer or distributor can become the manufacturer for LVD purposes if it places electrical equipment on the market under its own name or trade mark, or modifies electrical equipment in a way that may affect compliance. The same risk applies when a service organization markets a replacement assembly as its own compliant product rather than acting only as a repair channel.

A normal repair using an identical or similar spare part usually does not require a new conformity assessment of the already placed product when the repair maintains or restores the original condition. The Blue Guide distinguishes that from important changes or overhauls that modify original performance, purpose, type, hazards, or risk level; those changes can make the modified product a new product with manufacturer obligations.

For LVD spare parts, keep records long enough to answer both market-surveillance and product-safety questions. The Directive requires manufacturers to keep technical documentation and the EU declaration for 10 years after electrical equipment has been placed on the market, and it requires traceability information to be presentable for 10 years after supply.

LVD Article 12 ties presumption of conformity to harmonised standards, or parts of standards, whose references have been published in the Official Journal of the European Union. If an OJEU decision later withdraws that reference, the manufacturer should treat the old citation as time-limited rather than permanent.

The withdrawal does not automatically prove that every product is unsafe. It does mean the manufacturer should no longer rely on the withdrawn reference after the applicable withdrawal date as the OJEU basis for presumption of conformity. The file should show either reliance on the replacement OJEU reference, a justified partial application, or another technical solution demonstrating the LVD safety objectives.

For example, Implementing Decision (EU) 2025/1488 publishes replacement references for EN 50214:2024 and EN 50620:2017 with amendments A1:2019 and A2:2024, while deleting the earlier rows for EN 50214:2006 and EN 50620:2017. That deletion point applies from 23 January 2027, giving manufacturers time to adapt covered equipment.

Use the withdrawal or application date in the specific OJEU decision or annex row, not the publication date of a standards-body document and not a generic company review date. The date can differ by standard, by amendment, and by OJEU annex.

Implementing Decision (EU) 2023/2723 consolidated LVD harmonised standard references and included withdrawal tables. Its Annex II lists EN 60335-2-24:2010 for refrigerating appliances with a withdrawal date of 13 June 2025, while other listed standards in the same annex have different withdrawal dates such as 11 July 2024 or 17 September 2024. Annex III also lists many cable-related references with 13 June 2025 withdrawal dates.

Those dates are examples from grounded OJEU rows. They should not be copied to unrelated standards. For each product, verify the exact standard reference, amendments, restrictions, and withdrawal date that match the cited technical documentation.

LVD Article 6 requires manufacturers to draw up technical documentation, carry out the Annex III conformity assessment procedure, draw up an EU declaration of conformity, and keep the technical documentation and EU declaration for 10 years after the equipment is placed on the market. Article 6 also says changes in product design or characteristics and changes in the harmonised standards used to declare conformity must be adequately taken into account.

Annex III requires the technical documentation to include an adequate analysis and assessment of risks and, where applicable, a list of harmonised standards applied in full or in part. If harmonised standards are not applied, or are only partly applied, the documentation must describe the solutions adopted to meet the LVD safety objectives.

A standards-withdrawal review should therefore update the standards list, the risk assessment, test-report mapping, production-control basis, instructions or warnings where affected, and the EU declaration of conformity if the declaration identifies the old standard reference.

Do not treat a replacement standard as a universal safe harbour. Presumption of conformity depends on the OJEU-published reference, the safety objectives covered, any restrictions, and whether the product actually conforms to the cited standard or parts of it.

Do not treat a deferred withdrawal as permission to ignore the change until the last day. The deferral exists so manufacturers can adapt covered equipment. Products placed on the market after the withdrawal date should have a current conformity basis documented before release.

Do not assume a notified body step is required under the LVD simply because a standard changed. The LVD conformity assessment route is internal production control under Annex III; the manufacturer's file must make the conformity basis traceable.

Directive 2014/35/EU 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 exclusion applies. The Commission LVD guide explains that the relevant rating is the rated electrical input or output, not every voltage that may appear inside the equipment.

A battery-operated device whose supply rating is below 50 V AC and below 75 V DC is outside the LVD voltage range when assessed on its own. If the same finished product has an integrated mains supply, or another rated input or output inside the LVD bands, assess that finished configuration under the LVD.

The charger or external power supply should be assessed as its own electrical equipment. The Commission guide states that an accompanying battery charger, and equipment with an integrated power supply unit within the LVD voltage ranges, are in the scope of the LVD.

This means a single consumer bundle can contain two different scope answers: the battery device may be outside the LVD voltage band, while the mains charger, USB power adapter, dock, or detachable external supply is inside the LVD because of its own rated input or output.

For equipment that is in LVD scope, the safety assessment is not limited to electric shock. The Commission guide describes the LVD as covering all safety aspects of electrical equipment, including non-electrical hazards arising from that equipment.

The technical documentation should connect the scope answer to the actual hazards of the battery product or supply configuration: rated supply, insulation, overheating, overload, mechanical protection, environmental influences, instructions, warnings, standards used, examinations, and test reports.

Use the LVD file to route safety obligations for electrical equipment within the LVD voltage bands. Use separate routing for other Union acts that apply to the same marketed product or bundle, and make the EU declaration identify the applicable Union acts when more than one declaration regime applies.

For radio products, the LVD guide says radio equipment within the RED scope is not subject to the LVD, while RED Article 3(1) refers to safety requirements identical to the LVD and to EMC essential requirements. For non-radio electrical equipment, EMC can still apply to electromagnetic disturbance while the LVD covers safety aspects, including electromagnetic aspects where they relate to safety.

The useful record is a short product-specific scope note, not a generic statement that the product is battery powered. It should identify every electrical item in the marketed configuration and give a separate conclusion for each item.

For each item, record the rated input and output, whether the LVD voltage band is met, whether Annex II or RED changes the route, which standards or technical specifications are used, and where the declaration and test evidence sit.

Article 1 of Directive 2014/35/EU applies to electrical equipment designed for use with a voltage rating of 50-1000 V AC or 75-1500 V DC. Equipment outside those design ratings is not brought into LVD scope by the voltage bands alone.

The LVD guide clarifies that voltage rating means the rated electrical input or rated electrical output, or both. It is not a test of transient, generated, or otherwise internal voltages that may appear inside the equipment during operation.

Use the product's stated electrical ratings, not a generic product category label. The guide says equipment is designed for use within the LVD range when it has a rated input voltage, a rated output voltage, or both inside the range.

For products with more than one rating, assess the rated inputs and outputs that define the product as placed on the EU market. A low-voltage device, a mains adapter, and a charger bundled with it may need separate scope conclusions if they are separate electrical equipment.

Being inside 50-1000 V AC or 75-1500 V DC is not the end of the scope check. Article 1 excludes the equipment and phenomena listed in Annex II, and the LVD guide describes that Annex II list as exhaustive for explicit LVD exclusions.

The Annex II exclusions cover specific product types or situations, not every product with electrical hazards. If no Annex II exclusion applies, continue with LVD safety objectives, conformity assessment, technical documentation, EU declaration of conformity, and CE marking where the product is otherwise in scope.

Most mistakes come from treating the product family as the answer instead of reading the rated electrical boundaries of the exact equipment. The same commercial bundle can contain one item outside the LVD voltage band and another item inside it.

The threshold conclusion should name the exact equipment assessed, its rated inputs and outputs, whether Annex II applies, and whether another EU product regime such as RED, machinery, ATEX, medical-device, lift, or marine-equipment law is doing the main work.

The threshold file should be short but product-specific. It should let a reviewer see why the equipment is inside the LVD band, outside the band, or excluded despite being inside the band.

For in-scope equipment, keep the threshold memo with the technical documentation required by Annex III, including the product description, drawings or schemes where relevant, applicable requirements, standards or other technical specifications used, design calculations or examinations, and test reports.