Artifact GuideEU

EU Low Voltage Directive Internal Production Control

The Low Voltage Directive covers electrical equipment designed for use within the EU voltage limits and focuses on safety objectives, technical documentation, EU declaration, and CE marking.

Use this page to document Module A self-assessment without adding notified-body steps that the LVD production phase does not require.

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Author

Sorena AI

Published

May 9, 2026

Updated

May 9, 2026

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Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated May 9, 2026

Overview

Internal production control is the Low Voltage Directive conformity assessment route in Annex III. The manufacturer establishes the technical documentation, checks the design and manufacturing process against the LVD safety objectives, affixes CE marking to compliant equipment, and keeps the EU declaration of conformity with the technical file for market surveillance authorities.

Section 1

What Module A requires from the manufacturer

Under Annex III, internal production control is a self-assessment procedure. The manufacturer ensures and declares on its sole responsibility that the electrical equipment satisfies the applicable LVD requirements. The LVD guide describes this as the manufacturer carrying out the product and quality-system assessment procedure itself.

For an LVD release file, treat Module A as four connected records: the product scope and safety-objective assessment, the technical documentation, the manufacturing controls that keep series production aligned with that documentation, and the signed EU declaration plus CE marking evidence.

Confirm the product is electrical equipment within the LVD voltage bands and is not excluded by Annex II before using an LVD Module A file.
Map hazards to the Annex I safety objectives for persons, domestic animals, and property, including reasonably foreseeable use conditions.
Assign the manufacturer role carefully: an importer or distributor that sells under its own name or modifies equipment in a way that may affect conformity takes on manufacturer obligations.
Do not add a notified-body certificate to the LVD production file unless another applicable Union act or product regime independently requires one.

Sources for this answer

Directive 2014/35/EU on electrical equipment within certain voltage limits

Annex III defines internal production control as the manufacturer's own conformity assessment procedure.

European Commission LVD Guide

Explains that LVD Module A does not require notified-body involvement in the production phase.

Section 2

Technical documentation contents

Annex III requires the manufacturer to establish technical documentation that makes it possible to assess conformity with the relevant LVD requirements. The file must include an adequate analysis and assessment of risks and cover, as relevant, the design, manufacture, and operation of the electrical equipment.

The technical file should be usable without project memory. It should identify the equipment model, explain drawings and circuit schemes, connect tests and calculations to the safety objectives, and show which standards or other technical solutions were used.

Keep a general product description, conceptual design and manufacturing drawings, component and sub-assembly schemes, and explanations needed to understand operation.
List harmonised standards applied in full or part and identify the parts applied when a standard is only partly used.
Where harmonised, international, or national standards are not used, describe the technical solutions adopted to meet the LVD safety objectives.
Attach design calculations, examinations, and test reports that support the conformity conclusion.

Sources for this answer

Directive 2014/35/EU on electrical equipment within certain voltage limits

Annex III lists the required technical documentation elements for Module A.

European Commission LVD Guide

Clarifies that a product risk analysis remains necessary even when harmonised standards are used.

Section 3

Harmonised standards and safety objectives

Harmonised standards are voluntary, but when their references are published in the Official Journal they can give a presumption of conformity for the safety objectives they cover. The Module A file should therefore record exactly which standards were used, whether they were used fully or partly, and whether any restrictions, withdrawals, or formal objections affect the claim.

A standards list is not enough. The file still needs the product-specific risk assessment, because the LVD guide warns that products can include techniques or risks not addressed when a harmonised standard was drafted.

Check that each cited harmonised standard reference is published for the LVD and covers the relevant safety objective and product feature.
Record the product risks addressed by each standard and the risks handled through another technical solution.
When a standard is partly applied, identify the clauses or parts used instead of treating the whole standard as evidence.
Reopen the standards assessment after material design changes, component substitutions, firmware changes affecting safety, test failures, complaints, or updates to OJEU references.

Sources for this answer

Directive 2014/35/EU on electrical equipment within certain voltage limits

Article 12 gives presumption of conformity for covered safety objectives when OJEU-published harmonised standards are used.

European Commission - harmonised standards overview

Commission overview confirming voluntary use of harmonised standards and the role of OJEU references.

European Commission LVD harmonised standards page

Commission LVD standards page used to anchor the need to check current LVD OJEU standard references.

Section 4

Manufacturing controls, EU declaration, and retention

Module A does not stop at design review. The manufacturer must take the measures necessary so the manufacturing process and its monitoring keep manufactured equipment in line with the technical documentation and the applicable LVD requirements.

After conformity has been demonstrated, the manufacturer draws up the EU declaration of conformity, affixes CE marking to each compliant item, and keeps the declaration with the technical documentation available to national market surveillance authorities for 10 years after the equipment has been placed on the market.

Tie production checks, inspection criteria, supplier controls, nonconformity handling, and change control back to the released technical documentation.
Keep the EU declaration continuously updated, translated as required by the Member State where the equipment is placed or made available, and traceable to the product model.
Use a single EU declaration or declaration dossier when the same equipment is subject to more than one Union act requiring a declaration.
Prepare to provide conformity information and documentation in paper or electronic form after a reasoned request from a competent national authority, and to cooperate on risk-elimination actions.

Sources for this answer

Directive 2014/35/EU on electrical equipment within certain voltage limits

Articles 6, 15, 17, and Annex III support production consistency, declaration, CE marking, retention, and authority-cooperation points.

European Commission LVD Guide

Explains the three core LVD Module A elements: technical documentation, declaration of conformity, and CE marking.

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Primary sources