--- title: "LVD Internal Production Control: Module A Evidence" canonical_url: "https://www.sorena.io/artifacts/eu/low-voltage-directive/internal-production-control" source_url: "https://www.sorena.io/artifacts/eu/low-voltage-directive/internal-production-control" author: "Sorena AI" description: "How manufacturers document Low Voltage Directive Module A: technical documentation, safety objectives, harmonised standards, EU declaration, CE marking, and production controls." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Low Voltage Directive" - "LVD" - "Directive 2014/35/EU" - "Internal Production Control" - "LVD compliance" - "LVD evidence" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # LVD Internal Production Control: Module A Evidence How manufacturers document Low Voltage Directive Module A: technical documentation, safety objectives, harmonised standards, EU declaration, CE marking, and production controls. *Artifact Guide* *EU* ## 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. 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. ## 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](https://eur-lex.europa.eu/eli/dir/2014/35/oj?ref=sorena.io) - Annex III defines internal production control as the manufacturer's own conformity assessment procedure. - [European Commission LVD Guide](https://ec.europa.eu/docsroom/documents/31221?ref=sorena.io) - Explains that LVD Module A does not require notified-body involvement in the production phase. ## 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](https://eur-lex.europa.eu/eli/dir/2014/35/oj?ref=sorena.io) - Annex III lists the required technical documentation elements for Module A. - [European Commission LVD Guide](https://ec.europa.eu/docsroom/documents/31221?ref=sorena.io) - Clarifies that a product risk analysis remains necessary even when harmonised standards are used. ## 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](https://eur-lex.europa.eu/eli/dir/2014/35/oj?ref=sorena.io) - Article 12 gives presumption of conformity for covered safety objectives when OJEU-published harmonised standards are used. - [European Commission - harmonised standards overview](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards_en?ref=sorena.io) - Commission overview confirming voluntary use of harmonised standards and the role of OJEU references. - [European Commission LVD harmonised standards page](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/low-voltage-lvd_en?ref=sorena.io) - Commission LVD standards page used to anchor the need to check current LVD OJEU standard references. ## 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](https://eur-lex.europa.eu/eli/dir/2014/35/oj?ref=sorena.io) - Articles 6, 15, 17, and Annex III support production consistency, declaration, CE marking, retention, and authority-cooperation points. - [European Commission LVD Guide](https://ec.europa.eu/docsroom/documents/31221?ref=sorena.io) - Explains the three core LVD Module A elements: technical documentation, declaration of conformity, and CE marking. *Recommended next step* *Placement: after implementation section* ## Use this LVD guide as a cited evidence workflow Turn this EU Low Voltage Directive page into a repeatable workflow for product, legal, quality, procurement, support, and engineering teams. Keep citations, owners, evidence, and review triggers together. - [Open Research Copilot](/solutions/research-copilot.md): Answer LVD scope, timing, and interpretation questions with cited outputs. - [Talk through implementation](/contact.md): Review your scope, evidence model, controls, and next actions. ## Primary sources - [Directive 2014/35/EU on electrical equipment within certain voltage limits](https://eur-lex.europa.eu/eli/dir/2014/35/oj?ref=sorena.io) - Binding source for LVD scope, manufacturer obligations, Module A internal production control, technical documentation, EU declaration, CE marking, retention, and authority cooperation. - Quote: "Internal production control" - [European Commission LVD Guide](https://ec.europa.eu/docsroom/documents/31221?ref=sorena.io) - Commission guidance used for Module A implementation detail, including risk assessment, production consistency, and the no-notified-body point for LVD production-phase Module A. - Quote: "Module A" - [European Commission - harmonised standards overview](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards_en?ref=sorena.io) - Commission overview for voluntary harmonised standards, OJEU reference lists, and presumption-of-conformity context. - Quote: "published in the Official Journal" - [European Commission LVD harmonised standards page](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/low-voltage-lvd_en?ref=sorena.io) - Commission page used for the current LVD harmonised-standards list context and the need to verify OJEU references. - Quote: "Low voltage (LVD)" ## Related Topic Guides - [Are chargers and power adapters covered by the EU Low Voltage Directive? | LVD FAQ](/artifacts/eu/low-voltage-directive/faq/chargers-and-adapters.md): LVD FAQ for chargers, external power supplies, travel adapters, CE marking, technical documentation, instructions, harmonised standards, and EMC, RED, and RoHS overlap. - [Are components covered by the Low Voltage Directive? | LVD FAQ](/artifacts/eu/low-voltage-directive/faq/components.md): How the LVD treats basic components, electrical components intended for incorporation, CE marking, and evidence for finished electrical equipment. - [EU Low Voltage Directive applicability test](/artifacts/eu/low-voltage-directive/applicability-test.md): Check whether electrical equipment falls under the EU Low Voltage Directive by voltage rating, Annex II exclusions, components, evaluation kits, batteries, CE marking, and adjacent EU product rules. - [EU Low Voltage Directive compliance guide](/artifacts/eu/low-voltage-directive/compliance.md): Concrete LVD compliance guide covering scope, safety objectives, manufacturer duties, internal production control, EU declaration, CE marking, technical documentation, labels, importer and distributor checks, and post-market action. - [EU Low Voltage Directive deadlines and compliance calendar](/artifacts/eu/low-voltage-directive/deadlines-and-compliance-calendar.md): Calendar checkpoints for LVD 2014/35/EU: current-law status, release evidence gates, OJEU standard withdrawals, 10-year records, and post-market triggers. - [EU Low Voltage Directive exclusion triage workflow](/artifacts/eu/low-voltage-directive/exclusion-triage-workflow.md): A concrete LVD exclusion triage workflow for voltage scope, Annex II exclusions, components, evaluation kits, radio equipment, EMC, Machinery, and evidence records. - [EU Low Voltage Directive FAQ: scope, duties, CE marking](/artifacts/eu/low-voltage-directive/faq.md): Answers to practical LVD questions on voltage limits, Annex II exclusions, batteries, chargers, components, economic operators, instructions, standards, CE marking, and post-market controls. - [EU Low Voltage Directive post-market controls](/artifacts/eu/low-voltage-directive/post-market-controls.md): LVD post-market controls for corrective action, recalls, complaints, technical documentation, EU declarations, authority cooperation, and 2019/1020 market surveillance. - [EU Low Voltage Directive requirements](/artifacts/eu/low-voltage-directive/requirements.md): LVD requirements for voltage scope, Annex I safety objectives, economic operator duties, internal production control, technical files, EU declarations, CE marking, standards, and market surveillance. - [EU Low Voltage Directive scope and covered products](/artifacts/eu/low-voltage-directive/scope-and-products.md): Scope notes for the EU Low Voltage Directive: voltage limits, Annex II exclusions, components, chargers, adapters, and boundaries with RED, Machinery, and EMC rules. - [EU LVD standard selection and OJEU checks](/artifacts/eu/low-voltage-directive/standard-selection.md): How to select Low Voltage Directive harmonised standards, check OJEU status, map Annex I safety objectives, and document alternatives in the technical file. - [Household Appliances under the Low Voltage Directive | LVD FAQ](/artifacts/eu/low-voltage-directive/faq/household-appliances.md): FAQ on how household and similar electrical appliances are treated under the EU Low Voltage Directive, including scope, safety objectives, CE marking, documentation, standards, and operator roles. - [Low Voltage Directive vs EMC Directive: safety and EMC comparison](/artifacts/eu/low-voltage-directive/low-voltage-directive-vs-emc-directive.md): Compare the EU Low Voltage Directive and EMC Directive by scope, safety objectives, electromagnetic disturbance, immunity, CE marking, declarations, documentation, and standards. - [Low Voltage Directive vs Machinery Regulation boundary](/artifacts/eu/low-voltage-directive/low-voltage-directive-vs-machinery-regulation.md): Grounded comparison of the LVD and EU machinery law boundary for electrical equipment, machine electrical hazards, control gear, documentation, and CE marking. - [LVD Annex II exclusions under Directive 2014/35/EU](/artifacts/eu/low-voltage-directive/annex-ii-exclusions.md): Practical EU Low Voltage Directive guide to Annex II excluded equipment, boundary cases, and records to keep when a product is outside LVD scope. - [LVD combined CE files for multi-regime products](/artifacts/eu/low-voltage-directive/combined-ce-files.md): How to keep EU declarations, standards, risk assessments, instructions, labels, and technical documentation aligned when LVD products also trigger EMC, RED, RoHS, machinery, or market-surveillance checks. - [LVD Compliance Checklist](/artifacts/eu/low-voltage-directive/checklist.md): EU Low Voltage Directive checklist covering scope, safety objectives, standards, technical documentation, EU declaration, CE marking, labelling, traceability, and post-market duties. - [LVD conformity assessment and CE marking](/artifacts/eu/low-voltage-directive/conformity-assessment-and-ce.md): EU Low Voltage Directive guide to internal production control, technical documentation, harmonised standards, EU declarations of conformity, and CE placement. - [LVD Conformity Assessment Template](/artifacts/eu/low-voltage-directive/lvd-conformity-assessment-template.md): Template fields for documenting Low Voltage Directive scope, Annex I safety objectives, standards, technical documentation, EU declaration, CE marking, and production control evidence. - [LVD Essential Safety Hazards and Objectives](/artifacts/eu/low-voltage-directive/essential-safety-hazards.md): EU Low Voltage Directive hazard map for Annex I safety objectives: electrical contact, heat, arcs, radiation, insulation, assembly, overload, mechanical, environmental, and foreseeable-use risks. - [LVD Essential Safety Requirements](/artifacts/eu/low-voltage-directive/essential-safety-requirements.md): Annex I safety objectives under the EU Low Voltage Directive: safe construction, markings, instructions, electrical hazards, external influences, insulation, temperature, and technical-file evidence. - [LVD harmonised standard update workflow](/artifacts/eu/low-voltage-directive/harmonized-standard-update-impact-workflow.md): Workflow for checking Low Voltage Directive harmonised standard updates, affected products, withdrawal dates, presumption of conformity, retesting, technical files, and declarations. - [LVD Harmonised Standards and OJEU Citations](/artifacts/eu/low-voltage-directive/harmonized-standards.md): Track Low Voltage Directive harmonised standards by OJEU reference, presumption of conformity, restrictions, withdrawals, replacements, and technical-file evidence. - [LVD importer obligations FAQ | Directive 2014/35/EU](/artifacts/eu/low-voltage-directive/faq/importers.md): What importers must check before placing LVD electrical equipment on the EU market: conformity assessment, CE marking, EU declaration, traceability, storage, corrective action, and authority cooperation. - [LVD instructions and labelling requirements | FAQ](/artifacts/eu/low-voltage-directive/faq/instructions-and-labelling.md): What the Low Voltage Directive requires for instructions, safety information, traceability, manufacturer/importer labels, CE marking, and retained evidence. - [LVD penalties and enforcement](/artifacts/eu/low-voltage-directive/penalties-and-fines.md): How penalties and enforcement work under the EU Low Voltage Directive: Member State penalty rules, market surveillance action, recalls, restrictions, and cooperation. - [LVD release evidence gates workflow](/artifacts/eu/low-voltage-directive/release-evidence-gates-workflow.md): Product-release gates for EU Low Voltage Directive evidence: voltage scope, safety objectives, standards, technical documentation, EU declaration, CE marking, labelling, production control, operator checks, and post-market triggers. - [LVD spare parts FAQ | CE marking and evidence](/artifacts/eu/low-voltage-directive/faq/spare-parts.md): How to handle spare parts under the EU Low Voltage Directive when a part is electrical equipment, built into finished equipment, imported, modified, or documented for repair. - [LVD Technical Documentation Checklist](/artifacts/eu/low-voltage-directive/technical-documentation.md): What to keep in EU Low Voltage Directive technical documentation: product identity, design and manufacturing records, risk assessment, standards, tests, declaration, CE marking, instructions, and authority access. - [LVD voltage scope triage workflow](/artifacts/eu/low-voltage-directive/voltage-scope-triage-workflow.md): A concrete Low Voltage Directive scope workflow for AC/DC thresholds, intended-use claims, Annex II exclusions, components, chargers, adapters, and RED, EMC, or Machinery routing. - [LVD voltage thresholds: 50-1000 V AC and 75-1500 V DC](/artifacts/eu/low-voltage-directive/voltage-thresholds.md): How the EU Low Voltage Directive voltage limits work for rated input and output voltage, battery-powered equipment, chargers, Annex II exclusions, and RED, EMC, or Machinery routing. - [LVD vs MSR: Low Voltage Directive and Market Surveillance Regulation](/artifacts/eu/low-voltage-directive/lvd-vs-msr.md): Compare LVD electrical-equipment conformity duties with Regulation (EU) 2019/1020 market surveillance, economic-operator cooperation, corrective action, online sales, and border controls. - [LVD vs RED: electrical safety and radio equipment scope](/artifacts/eu/low-voltage-directive/lvd-vs-red.md): Compare the Low Voltage Directive and Radio Equipment Directive for electrical safety, radio scope, CE files, chargers, adapters, and harmonised standards. - [LVD vs RoHS: electrical safety vs substance restriction](/artifacts/eu/low-voltage-directive/lvd-vs-rohs.md): Compare LVD and RoHS at the CE file boundary: electrical safety evidence, hazardous-substance restriction, declarations, standards, and documentation overlap. - [What happens when an LVD harmonised standard is withdrawn or replaced? | LVD FAQ](/artifacts/eu/low-voltage-directive/faq/standards-withdrawal.md): How LVD manufacturers should handle OJEU standard withdrawals, replacement references, presumption of conformity, technical documentation updates, and transition dates. - [When are battery-powered products covered by the Low Voltage Directive? | LVD FAQ](/artifacts/eu/low-voltage-directive/faq/battery-powered-products.md): LVD FAQ explaining when battery-only products, bundled chargers, adapters, external power supplies, and integrated supplies fall inside or outside Directive 2014/35/EU. - [Which AC and DC voltage thresholds bring equipment into the Low Voltage Directive? | LVD FAQ](/artifacts/eu/low-voltage-directive/faq/ac-and-dc-thresholds.md): LVD FAQ explaining the 50-1000 V AC and 75-1500 V DC scope thresholds, input and output ratings, exclusions, and common product edge cases. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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