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. 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.