LVD FAQ Standards Withdrawal

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 It does mean the manufacturer should no longer rely on the withdrawn reference after the applicable withdrawal date as the OJEU basis for presumption of conformity.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.