Boundary comparisonEU

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 placed on the EU market. Regulation (EU) 2023/1230 applies from 20 January 2027, with limited provisions applying earlier.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

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.

Review all sources
First framework
Low Voltage Directive

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.

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.

Machinery law

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.

Operational implication

Start the record with the product boundary, voltage rating, intended use, and whether the item is standalone electrical equipment or .

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.

Machinery law

Directive 2006/42/EC principally governs placed on the market through 19 January 2027, while Chapter VI of Regulation (EU) 2023/1230 has applied to those products, instead of Article 11 of the Directive, since 19 July 2023. The Regulation applies generally from 20 January 2027, apart from other specified provisions with earlier dates.

Operational implication

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.

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.

Machinery law

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.

Operational implication

Do not treat every powered product as LVD equipment; check the listed categories, intended use, moving/mechanical elements, and product information.

Intended-use boundary

Low Voltage Directive

Household appliances intended for domestic use can remain on the LVD side where the product information and declaration support that intended use.

Machinery law

The LVD Guide says household appliances intended specifically for commercial or industrial use are excluded from the LVD and included in the Directive scope.

Operational implication

Use the manufacturer statement in the declaration, product information, instructions, and advertising to support the intended-use classification.

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.

Machinery law

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.

Operational implication

Use one evidence index if useful, but tag each item to the product law it supports: LVD technical file, machine technical file, or both.

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.

Machinery law

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.

Operational implication

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.

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.

Machinery law

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.

Operational implication

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.

Overlap and reuse

Low Voltage Directive

LVD harmonised standards published in the OJEU can support presumption of conformity with the covered LVD safety objectives.

Machinery law

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.

Operational implication

Do not rely on a standard number alone; check the product, annex information, directive allocation, and whether the standard supports LVD, , or both.

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.

Machinery law

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.

Operational implication

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.
Section 1

The boundary is not electrical risk alone

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 principally by Directive 2006/42/EC, while Chapter VI of Regulation (EU) 2023/1230 has applied to those products, instead of Article 11 of the Directive, since 19 July 2023. Machinery placed on the market from 20 January 2027 must be assessed under Regulation (EU) 2023/1230. Separate application dates in Article 54 cover other 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.
Section 2

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.
Recommended next step

Review the product-law boundary before release

Use the boundary record to align product scope, electrical safety evidence, machinery evidence, declarations, and CE marking before market placement.

Section 3

CE documentation must name the right product law

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.
Primary sources

References and citations

ec.europa.eu16 citations
Referenced sections
  • Provides the specific LVD-Machinery Directive boundary guidance used for this page, including electrical machinery and low-voltage switchgear/control gear.
  • Explains the LVD and Machinery Directive boundary, including electrical hazards in machinery and declaration treatment.
  • Supports the switchgear/controlgear boundary and the rule that machinery electrical hazards must meet LVD safety objectives while machinery law governs the machine declaration route.
Show 13 more
  • Supports the machinery declaration boundary where electrical machinery must meet LVD safety objectives but the declaration should refer to machinery law.
  • Supports the Machinery Directive boundary for electrical and electronic products.
  • Supports the listed electrical/electronic categories excluded from the Machinery Directive when covered by LVD.
  • Supports examples and criteria for machinery-side classification in the LVD Guide.
  • Supports the domestic-use criterion and manufacturer-stated intended use.
  • Supports the commercial/industrial-use classification for machinery-side treatment.
  • Supports the declaration boundary for machinery with electrical supply.
  • Supports the electrical-hazards-in-machinery boundary and declaration treatment.
  • Supports this page's low-voltage switchgear/control gear treatment analysis under the LVD boundary.
  • Supports keeping electrical safety objectives in view for machinery with electrical supply.
  • Supports EN 60335 allocation criteria between LVD and Machinery Directive.
  • Supports examples where other product laws interact with or displace LVD treatment.
  • Supports the boundary record for machinery, switchgear/controlgear, intended use, and electrical safety objectives.
"clarifies the borderline"
More quoted passages
"machinery with an electrical supply"
"low-voltage switchgear and control gear"
"should not refer to the LVD"
"meet the definitions"
"power tool and lawnmowers"
"intended for domestic use"
"commercial or industrial use"
"electrical hazards"
"switchgear and controlgear"
"allocation of standards under LVD or MD"
"other EU legislation"
"the criterion to be taken into account"
eur-lex.europa.eu11 citations
Referenced sections
  • Defines LVD scope, exclusions, safety objectives, conformity assessment, EU declaration, technical documentation, and CE-marking rules.
  • Defines the LVD voltage band, safety objectives, manufacturer documentation, EU declaration, and CE-marking duties for covered electrical equipment.
  • Requires technical documentation that covers design, manufacture, operation, applied standards, assessments, and test reports for covered electrical equipment.
Show 8 more
  • Supports LVD technical documentation, EU declaration, 10-year retention, single declaration, and CE-marking requirements.
  • Supports the LVD voltage band and Annex II exclusion check.
  • Primary LVD legal source for the electrical-equipment side of the comparison.
  • Supports LVD internal production control, technical documentation, EU declaration, CE marking, and retention.
  • Supports the LVD safety-objectives benchmark.
  • Supports the LVD voltage-limit and technical-documentation checks for electrical equipment.
  • Supports presumption of conformity from harmonised standards whose references are published in the OJEU.
  • Supports the LVD record set: technical documentation, applied standards, risk assessment, test reports, EU declaration, and CE marking.
"electrical equipment designed for use within certain voltage limits"
More quoted passages
"between 50 and 1 000 V"
"technical documentation"
"single EU declaration of conformity"
"between 75 and 1 500 V"
"within certain voltage limits"
"for 10 years"
"safety objectives"
"electrical equipment"
"presumed to be in conformity"
"adequate analysis and assessment"
single-market-economy.ec.europa.eu4 citations
Referenced sections
  • Commission page used only to ground that Machinery is listed as Regulation (EU) 2023/1230 replacing Directive 2006/42/EC in the product-law framework.
  • Lists Low Voltage and Machinery in the EU product-law framework and identifies Regulation (EU) 2023/1230 as replacing Directive 2006/42/EC.
  • Supports the broader product-legislation context including Low Voltage and Machinery.
Show 1 more
  • Supports the current product-law framework context for Low Voltage and Machinery.
"Regulation (EU) 2023/1230"
More quoted passages
"Machinery - Regulation (EU) 2023/1230"
"Alignment of product legislation"
"Low Voltage - Directive 2014/35/EU"
single-market-economy.ec.europa.eu3 citations
Referenced sections
  • Explains how harmonised standards support EU product legislation through OJEU references and presumption of conformity.
  • Explains harmonised standards and OJEU publication context for presumption of conformity.
  • Explains harmonised standards, OJEU references, and presumption-of-conformity context.
"Harmonised standards are European standards"
More quoted passages
"OJEU"
eur-lex.europa.eu3 citations
Referenced sections
  • Binding source for the machinery scope and exclusions, conformity routes, declarations, repeal of Directive 2006/42/EC, and application from 20 January 2027 with specified earlier dates.
  • Articles 51, 52 and 54 support repeal of Directive 2006/42/EC from 20 January 2027, the main application date, the transition for products placed on the market before that date, and the limited provisions that apply earlier.
  • Articles 51, 52 and 54 establish the repeal and main application date, the transition for products placed on the market before that date, and the provisions that apply earlier.
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