LVD FAQ Spare Parts

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. Member States have applied the recast Directive's substantive provisions since 20 April 2016. 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 repair using an identical or similar spare part does not require a new conformity assessment of the already placed product when the work maintains or restores its original condition. A better-performing replacement made available through technical progress does not by itself make the repaired product new when performance remains within the intended use, range, and maintenance considered at the design stage.

The Blue Guide uses a case-by-case test for an important change or overhaul. A modified product must be treated as new when its original performance, purpose, or type changes beyond the initial risk assessment, the nature of a hazard changes or the risk level increases, and the product is then made available or put into service where the applicable law covers that event. The person carrying out that substantial modification takes the manufacturer obligations for the modified product.

A used item already placed on the EU market is not placed on the market again merely because it is resold. By contrast, used or second-hand electrical equipment imported from outside the EU and supplied in the EU for the first time is treated as a first EU placement and must meet the Union rules applicable at that time. Record the unit identity, origin, first-EU-supply evidence, configuration, condition, and responsible economic operator instead of relying on an age or resale label.

Refurbishment also needs a role decision. A business that releases refurbished equipment under its own name or trademark, or changes it in a way that may affect LVD compliance, assumes manufacturer duties. If the work only restores the original compliant condition, keep the repair basis and post-repair checks; if the work creates a new product or a substantial modification, complete the applicable conformity assessment, technical documentation, declaration, marking, instructions, and traceability before release.

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.