Low Voltage Directive vs Machinery Regulation electrical and machinery boundary
The LVD applies to electrical equipment in the 50-1000 V AC or 75-1500 V DC range unless an LVD exclusion or another product law takes the product outside the LVD route.
Until 19 January 2027, Directive 2006/42/EC governs most machinery placed on the EU market. Regulation (EU) 2023/1230 applies from 20 January 2027, with limited provisions applying earlier.
First decide whether the marketed product is or one of the electrical and electronic product categories excluded from machinery law when covered by the LVD. Until 19 January 2027, the Machinery Directive 2006/42/EC is the main machinery route. Regulation (EU) 2023/1230 applies from 20 January 2027, subject to its staggered provisions. Machinery with an electrical supply must address the LVD safety objectives for electrical hazards, but the final machinery conformity assessment and declaration follow machinery law.
Boundary comparison
LVD vs machinery law: product boundary and transition
A source-based comparison for electrical equipment and , including intended use, electrical hazards, declarations, and the 20 January 2027 transition to Regulation (EU) 2023/1230.
Use the LVD column for electrical equipment in the LVD voltage range, LVD exclusions, safety objectives, internal production control, technical documentation, EU declaration, and CE marking.
Second framework
Machinery law
Use the column for products within the Machinery Directive through 19 January 2027 and within Regulation (EU) 2023/1230 from 20 January 2027, including machinery with an electrical supply.
LVD vs machinery law: product boundary and transition
The LVD Guide says electrical and electronic products that do not fall into listed Directive exclusions, but meet the Machinery Directive definition, are in machinery scope.
Directive 2014/35/EU has applied since 20 April 2016 to covered electrical equipment. The product's placement date does not move it into the Regulation.
Directive 2006/42/EC governs placed on the market through 19 January 2027. Regulation (EU) 2023/1230 applies from 20 January 2027, apart from specified provisions with earlier dates.
Record the placement date and use the instrument in force for that date; do not prepare a 2026 declaration as though the Machinery Regulation already controlled it.
The LVD Guide lists categories such as household appliances intended for domestic use, audio/video equipment, IT equipment, ordinary office , low-voltage switchgear and control gear, and electric motors as electrical/electronic products excluded from the Machinery Directive when covered by LVD.
Products outside those listed categories may still be if they meet the machinery definition; the LVD Guide gives power tools, lawnmowers, and electrically operated furniture with a motor and additional mechanical elements as machinery-side examples.
The LVD Guide says household appliances intended specifically for commercial or industrial use are excluded from the LVD and included in the Directive scope.
For covered LVD equipment, the manufacturer draws up technical documentation, performs internal production control, draws up the EU declaration of conformity, keeps the declaration and technical documentation for 10 years, and affixes CE marking.
For with electrical supply, the LVD Guide says the manufacturer declaration should not refer to the LVD but to machinery law, even though the LVD safety objectives are used for electrical hazards.
The LVD safety objectives cover health and safety of persons, domestic animals, and property for covered electrical equipment and can provide the electrical safety benchmark.
For with electricity supply, the LVD Guide says electrical hazards must be prevented and the LVD safety objectives apply, but machinery law governs conformity assessment and market placement for those hazards.
A separately placed control cabinet or assembly may be LVD electrical equipment when it is low-voltage switchgear/control gear or otherwise covered electrical equipment within the LVD voltage limits.
When the same electrical equipment is incorporated into , the machinery file needs traceable electrical safety evidence, and the final machine route may govern the declaration.
Separate the cabinet-as-product evidence from the machine-as-final-product evidence, especially where suppliers provide panels, drives, motors, protective devices, and wiring assemblies.
The LVD Guide notes that some EN 60335 standards may be allocated under LVD, Directive, or both, depending on product type and criteria such as moving parts or commercial use.
The LVD may apply alongside or be displaced by other product laws depending on the product, such as radio equipment, gas appliances, lifts, ATEX equipment, or other Union harmonisation legislation.
law is only one possible comparator; the LVD Guide also explains examples where other product laws govern the finished product or specific risks while LVD electrical safety objectives remain relevant for components or hazards.
Name the controlling product law before drafting the declaration, and keep a cited note explaining whether LVD is the main route, a complementary component route, or only an electrical safety benchmark.
Comparison row 1
Scope boundary
Low Voltage Directive
LVD applies to electrical equipment rated between 50 and 1000 V AC or 75 and 1500 V DC, except for Annex II exclusions.
The LVD Guide says electrical and electronic products that do not fall into listed Directive exclusions, but meet the Machinery Directive definition, are in machinery scope.
Start the record with the product boundary, voltage rating, intended use, and whether the item is standalone electrical equipment or .
Comparison row 2
Controlling law and date
Low Voltage Directive
Directive 2014/35/EU has applied since 20 April 2016 to covered electrical equipment. The product's placement date does not move it into the Regulation.
Directive 2006/42/EC governs placed on the market through 19 January 2027. Regulation (EU) 2023/1230 applies from 20 January 2027, apart from specified provisions with earlier dates.
Record the placement date and use the instrument in force for that date; do not prepare a 2026 declaration as though the Machinery Regulation already controlled it.
Comparison row 3
Trigger
Low Voltage Directive
The LVD Guide lists categories such as household appliances intended for domestic use, audio/video equipment, IT equipment, ordinary office , low-voltage switchgear and control gear, and electric motors as electrical/electronic products excluded from the Machinery Directive when covered by LVD.
Products outside those listed categories may still be if they meet the machinery definition; the LVD Guide gives power tools, lawnmowers, and electrically operated furniture with a motor and additional mechanical elements as machinery-side examples.
The LVD Guide says household appliances intended specifically for commercial or industrial use are excluded from the LVD and included in the Directive scope.
Use the manufacturer statement in the declaration, product information, instructions, and advertising to support the intended-use classification.
Comparison row 5
Evidence record
Low Voltage Directive
For covered LVD equipment, the manufacturer draws up technical documentation, performs internal production control, draws up the EU declaration of conformity, keeps the declaration and technical documentation for 10 years, and affixes CE marking.
For with electrical supply, the LVD Guide says the manufacturer declaration should not refer to the LVD but to machinery law, even though the LVD safety objectives are used for electrical hazards.
Use one evidence index if useful, but tag each item to the product law it supports: LVD technical file, machine technical file, or both.
Comparison row 6
Electrical hazards in machinery
Low Voltage Directive
The LVD safety objectives cover health and safety of persons, domestic animals, and property for covered electrical equipment and can provide the electrical safety benchmark.
For with electricity supply, the LVD Guide says electrical hazards must be prevented and the LVD safety objectives apply, but machinery law governs conformity assessment and market placement for those hazards.
Keep LVD-style electrical hazard evidence in the machine file, but do not turn that evidence into an LVD declaration if law controls the product.
Comparison row 7
Separately supplied equipment
Low Voltage Directive
A separately placed control cabinet or assembly may be LVD electrical equipment when it is low-voltage switchgear/control gear or otherwise covered electrical equipment within the LVD voltage limits.
When the same electrical equipment is incorporated into , the machinery file needs traceable electrical safety evidence, and the final machine route may govern the declaration.
Separate the cabinet-as-product evidence from the machine-as-final-product evidence, especially where suppliers provide panels, drives, motors, protective devices, and wiring assemblies.
Comparison row 8
Overlap and reuse
Low Voltage Directive
LVD harmonised standards published in the OJEU can support presumption of conformity with the covered LVD safety objectives.
The LVD Guide notes that some EN 60335 standards may be allocated under LVD, Directive, or both, depending on product type and criteria such as moving parts or commercial use.
Do not rely on a standard number alone; check the product, annex information, directive allocation, and whether the standard supports LVD, , or both.
Comparison row 9
Practical decision rule
Low Voltage Directive
The LVD may apply alongside or be displaced by other product laws depending on the product, such as radio equipment, gas appliances, lifts, ATEX equipment, or other Union harmonisation legislation.
law is only one possible comparator; the LVD Guide also explains examples where other product laws govern the finished product or specific risks while LVD electrical safety objectives remain relevant for components or hazards.
Name the controlling product law before drafting the declaration, and keep a cited note explaining whether LVD is the main route, a complementary component route, or only an electrical safety benchmark.
Practical decision rule
Documentation rule for the boundary record
State whether the item is standalone electrical equipment, , partly completed machinery, electrical equipment incorporated into machinery, or a product governed by another Union act.
Record the date of placing on the market. Use Directive 2006/42/EC through 19 January 2027 and Regulation (EU) 2023/1230 from 20 January 2027, subject to the Regulation's specific earlier application dates.
Keep voltage rating, intended use, product information, standards allocation, electrical safety evidence, and declaration references in the same boundary record.
Where law governs the final product, retain the LVD safety-objective analysis as evidence without naming the LVD as the declaration route unless another source supports doing so.
The LVD is scoped by electrical equipment designed for use within specified voltage limits, not by every product that has an electrical hazard. Directive 2014/35/EU applies to electrical equipment rated between 50 and 1000 V AC or between 75 and 1500 V DC, except for equipment and phenomena listed outside scope.
The LVD Guide states that with an electricity supply must meet the LVD safety objectives for electrical hazards, but the conformity assessment, placing on the market, putting into service, and declaration route for machinery are governed by machinery law. The electrical-safety benchmark can therefore come from LVD objectives even though the machine declaration does not list the LVD.
The transition date changes the controlling instrument, not the need to classify the product. Machinery placed on the market before 20 January 2027 remains governed by Directive 2006/42/EC. Machinery placed on the market from 20 January 2027 must be assessed under Regulation (EU) 2023/1230. Separate application dates in Article 54 cover specified provisions, so teams should not describe the whole Regulation as already applicable.
Use the LVD route for electrical equipment within the voltage band unless the LVD exclusions or a more specific product law displace it.
Use the route when the product is machinery and does not fall into a machinery-law exclusion that leaves it under LVD as electrical or electronic equipment.
Keep the electrical safety assessment traceable even where the declaration, not the LVD declaration, is the public conformity document.
Control gear, cabinets, and equipment incorporated in machines
The LVD Guide uses the internationally recognised meaning of electrical equipment and gives examples such as switchgear and controlgear. It also cites low-voltage switchgear and control gear among electrical and electronic product areas that can sit outside the Directive where they are covered by LVD.
For a control cabinet or control assembly, the practical evidence should show whether it is placed on the market as covered electrical equipment, supplied as low-voltage switchgear or control gear, or incorporated into a machine. If it is incorporated into , the machine file should still show how the electrical safety objectives were addressed.
Record the cabinet or assembly rating, intended use, product boundary, and whether it is supplied separately or only as part of .
For low-voltage switchgear and control gear supplied as products, document why the -law exclusion and LVD route apply. Incorporation into a machine does not remove the final machine manufacturer's duty to assess the assembled machine.
For incorporation, keep a bridge from the machine risk assessment to the electrical drawings, protective devices, circuits, test reports, and instructions.
Under the LVD, the manufacturer draws up technical documentation, carries out internal production control, draws up an EU declaration of conformity, keeps the technical documentation and declaration for 10 years after placing on the market, and affixes CE marking to covered electrical equipment.
Where the product is with an electrical supply, the LVD Guide says the machine must fulfil the LVD safety objectives for electrical hazards, but the declaration should refer to machinery law rather than the LVD. Before 20 January 2027, machinery uses the declaration required by Directive 2006/42/EC. From that date, Regulation (EU) 2023/1230 governs the EU declaration of conformity for machinery and the EU declaration of incorporation for partly completed machinery.
For standalone LVD electrical equipment, keep the LVD technical file, standards list, risk assessment, test reports, instructions, EU declaration, and CE-marking evidence together.
For , keep the electrical safety evidence in the machinery technical file and avoid naming the LVD on the declaration solely because electrical hazards were assessed.
For a machine subject to other applicable Union acts, identify those acts as required. Do not list the LVD solely because the electrical-hazard assessment used its safety objectives.