LVD vs RoHS Electrical safety vs substance restriction
The Low Voltage Directive is the electrical-equipment safety regime for products within 50-1000 V AC or 75-1500 V DC, unless an LVD exclusion applies.
The Restriction of Hazardous Substances (RoHS) Directive applies a separate product-scope and substance test to electrical and electronic equipment (EEE). It restricts ten substances in each , subject to exclusions and time-limited application exemptions.
A product can require both LVD and RoHS compliance, but the scope tests and evidence are different. LVD covers electrical safety for equipment rated 50-1000 V AC or 75-1500 V DC. RoHS covers electrical and electronic equipment in Annex I categories, generally up to 1000 V AC or 1500 V DC, and restricts ten substances in each unless an exclusion or application-specific exemption applies.
Side-by-side comparison
LVD vs RoHS: side-by-side comparison
A practical comparison of LVD electrical-safety scope and evidence with RoHS product categories, material-level restrictions, exclusions, exemptions, and documentation.
Electrical equipment safety regime for products within 50-1000 V AC or 75-1500 V DC, subject to LVD exclusions.
Second framework
RoHS
Substance-restriction regime for EEE in Annex I categories, generally up to 1000 V AC or 1500 V DC, subject to Article 2 exclusions and Annex III or IV exemptions.
LVD applies to electrical equipment designed for use with a voltage rating between 50 and 1,000 V AC or between 75 and 1,500 V DC, other than Annex II exclusions.
Supports the voltage bands and Annex II exclusion boundary.
other than the equipment and phenomena listed in Annex II
RoHS applies to EEE in the eleven Annex I categories. EEE must depend on electricity or electromagnetic fields for at least one intended function and be designed for no more than 1000 V AC or 1500 V DC, subject to Article 2 exclusions.
LVD technical documentation must allow assessment of conformity, include an adequate risk analysis and assessment, and cover design, manufacture, and operation as relevant.
Supports the LVD technical documentation content boundary.
include an adequate analysis and assessment of the risk(s)
RoHS documentation should connect the product breakdown to supplier evidence, material declarations, specifications, risk assessment, analytical results where needed, and each claimed exemption.
Supports LVD EU declaration and CE marking requirements.
draw up an EU declaration of conformity and affix the CE marking
RoHS also requires technical documentation, internal production control, an EU declaration, CE marking, and ten-year retention. A single technical documentation set may be used where the legal conditions are met.
Articles 7 and 13 to 15 support RoHS technical documentation, internal production control, EU declaration, CE marking, ten-year retention, and use of a single technical documentation set where permitted.
A combined declaration can reduce paperwork, but each listed act still needs its own supporting evidence.
LVD presumption of conformity depends on harmonised standards or parts of standards whose references have been published in the Official Journal and that cover the relevant LVD safety objectives.
RoHS harmonised standards can provide presumption of conformity for the requirements they cover. Substance evidence and any exemption record still need to match the actual product and materials.
Supports the LVD evidence components in Annex III and Article 6.
results of design calculations made, examinations carried out, etc.; and
RoHS Article 2 excludes specified equipment from scope. Annexes III and IV instead exempt narrowly described material or component applications, often for limited periods.
health and safety of persons and domestic animals, or property
RoHS operators must act on non-conforming EEE, maintain required records, provide information to authorities, and cooperate on corrective action according to their roles.
Articles 7, 9 and 10 support manufacturer, importer and distributor duties for non-conformity, records, information requests, and cooperation.
Use LVD safety conclusions for safety claims and RoHS substance conclusions for restricted-substance claims; do not treat either one as a substitute for the other.
LVD applies when the product is electrical equipment within the voltage limits and not excluded; then the file must contain the safety, standards, and CE-marking evidence tied to LVD.
health and safety of persons and domestic animals, or property
Apply RoHS when the product meets the EEE definition and Annex I category test and no Article 2 exclusion applies; then assess every against Annex II and any exact current exemption.
Articles 2 to 5 and Annexes I to IV support the RoHS scope, material-level restriction, and exemption decision sequence.
Complete both scope records, then build separate safety and substance evidence tracks under one controlled release index.
Scope boundary
LVD
LVD applies to electrical equipment designed for use with a voltage rating between 50 and 1,000 V AC or between 75 and 1,500 V DC, other than Annex II exclusions.
Supports the voltage bands and Annex II exclusion boundary.
other than the equipment and phenomena listed in Annex II
RoHS
RoHS applies to EEE in the eleven Annex I categories. EEE must depend on electricity or electromagnetic fields for at least one intended function and be designed for no more than 1000 V AC or 1500 V DC, subject to Article 2 exclusions.
Article 4 and Annex II support the ten restricted substances, homogeneous-material basis, and maximum concentrations.
Operational implication
Use LVD evidence for electrical safety and material-level RoHS evidence for restricted substances. Neither proves the other.
Technical documentation
LVD
LVD technical documentation must allow assessment of conformity, include an adequate risk analysis and assessment, and cover design, manufacture, and operation as relevant.
Supports the LVD technical documentation content boundary.
include an adequate analysis and assessment of the risk(s)
RoHS
RoHS documentation should connect the product breakdown to supplier evidence, material declarations, specifications, risk assessment, analytical results where needed, and each claimed exemption.
Supports LVD EU declaration and CE marking requirements.
draw up an EU declaration of conformity and affix the CE marking
RoHS
RoHS also requires technical documentation, internal production control, an EU declaration, CE marking, and ten-year retention. A single technical documentation set may be used where the legal conditions are met.
Articles 7 and 13 to 15 support RoHS technical documentation, internal production control, EU declaration, CE marking, ten-year retention, and use of a single technical documentation set where permitted.
Operational implication
A combined declaration can reduce paperwork, but each listed act still needs its own supporting evidence.
Evidence record
LVD
LVD presumption of conformity depends on harmonised standards or parts of standards whose references have been published in the Official Journal and that cover the relevant LVD safety objectives.
RoHS harmonised standards can provide presumption of conformity for the requirements they cover. Substance evidence and any exemption record still need to match the actual product and materials.
Supports the LVD evidence components in Annex III and Article 6.
results of design calculations made, examinations carried out, etc.; and
RoHS
RoHS Article 2 excludes specified equipment from scope. Annexes III and IV instead exempt narrowly described material or component applications, often for limited periods.
health and safety of persons and domestic animals, or property
RoHS
RoHS operators must act on non-conforming EEE, maintain required records, provide information to authorities, and cooperate on corrective action according to their roles.
Articles 7, 9 and 10 support manufacturer, importer and distributor duties for non-conformity, records, information requests, and cooperation.
Operational implication
Use LVD safety conclusions for safety claims and RoHS substance conclusions for restricted-substance claims; do not treat either one as a substitute for the other.
Overlap and reuse
LVD
LVD technical evidence can be reused across products only when the same voltage scope, safety objective, and applied standard basis still match.
Supports separate RoHS product-scope, homogeneous-material, conformity-documentation, and exemption conclusions.
Operational implication
One index can hold both workstreams, but each conclusion must remain traceable to the evidence and legal requirement it supports.
Practical decision rule
LVD
LVD applies when the product is electrical equipment within the voltage limits and not excluded; then the file must contain the safety, standards, and CE-marking evidence tied to LVD.
health and safety of persons and domestic animals, or property
RoHS
Apply RoHS when the product meets the EEE definition and Annex I category test and no Article 2 exclusion applies; then assess every against Annex II and any exact current exemption.
Articles 2 to 5 and Annexes I to IV support the RoHS scope, material-level restriction, and exemption decision sequence.
Operational implication
Complete both scope records, then build separate safety and substance evidence tracks under one controlled release index.
Practical decision rule
What should the CE file say?
First state whether the product falls in LVD scope by voltage range and exclusions, then cite the LVD safety evidence.
For RoHS, state the EEE category and exclusions checked, map the product into homogeneous materials, assess the ten substances, and record every exact exemption and date.
If the EU declaration covers more than one Union act, list each act and publication reference, and keep the supporting evidence tagged by act.
Reassess both files after relevant design, material, supplier, intended-function, voltage, standard, or exemption changes.
Supports RoHS scope, material-level restrictions, exemptions, technical documentation, declaration, CE marking, and change-control duties.
1
Section 1
Run two separate scope tests
LVD scope begins at 50 V AC or 75 V DC and ends at 1000 V AC or 1500 V DC. RoHS uses the same upper voltage values but no matching lower threshold: EEE is equipment that needs electric currents or electromagnetic fields for at least one intended function and is designed not to exceed 1000 V AC or 1500 V DC.
RoHS then asks whether the EEE falls within one of the eleven Annex I categories and whether an Article 2 exclusion applies. Exclusions include specified military and space equipment, equipment specifically designed only as part of excluded equipment, large-scale stationary industrial tools, large-scale fixed installations, certain transport and professional non-road mobile machinery, active implantable medical devices, specified photovoltaic panels, certain business-to-business research equipment, and pipe organs.
A product below the LVD lower voltage threshold can therefore be outside LVD but still inside RoHS. A mains product can be inside both. A large-scale fixed installation may be excluded from RoHS while electrical equipment supplied for it still needs a separate LVD analysis.
Record rated voltage, intended functions, Annex I category, and every claimed exclusion for the marketed product.
Do not infer RoHS scope from LVD scope or CE marking. Each act needs its own written conclusion.
For systems and installations, distinguish the complete installation, replaceable equipment, cables, components, and spare parts before applying an exclusion.
Supports general CE marking, conformity assessment, and Union harmonisation legislation context for products subject to more than one act.
products subject to Union harmonisation legislation
2
Section 2
Substance limits and exemptions
RoHS Article 4 limits lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP) to 0.1% by weight in each ; cadmium is limited to 0.01%. A homogeneous material is a uniform material, or a combination that cannot be separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding, or abrasion. The limit is not calculated against the finished product's total mass.
Annexes III and IV contain application-specific exemptions with their own scope and dates. An exemption is not a blanket approval for a substance or product family. Match the exact application, EEE category, material or component, concentration condition, and validity date. Because exemptions are amended and can expire, verify the current consolidated annex before each release and after a material, supplier, or design change.
Break the product into homogeneous materials rather than testing only the assembled product or averaging concentrations across parts.
Use supplier declarations, material declarations, specifications, bills of materials, risk-based assessment, and test reports as appropriate to support each material conclusion.
For every exemption, record the annex entry, exact application, covered category, affected part and substance, evidence, expiry status, and replacement plan.
Article 3(20), Article 4, Article 5 and Annexes II to IV support the homogeneous-material test, ten restricted substances and maximum concentrations, and application-specific exemption system.
Supports the general concept that product files may need to account for multiple applicable Union harmonisation acts.
Union harmonisation legislation
3
Section 3
Build one release index with separate evidence
Both directives require manufacturer technical documentation, internal production control, an EU declaration of conformity, CE marking, and ten-year retention after placing the product on the market. Those shared mechanics allow one controlled release index and, where the applicable acts permit, one EU declaration that identifies both acts. They do not allow one evidence set to prove two different requirements.
The LVD file should show voltage scope, Annex I safety objectives, risk assessment, design and manufacturing information, applied standards or other solutions, examinations, and safety test reports. The RoHS file should show category and exclusion decisions, the product's material and component breakdown, supplier and analytical evidence, the assessment method, exemptions, change control, and the RoHS conclusion.
Harmonised standards give presumption of conformity only for the requirements they cover. Record the exact standard edition, OJEU reference, parts applied, product configuration, and requirement supported. A safety standard does not establish substance conformity, and a RoHS technical-documentation standard does not establish electrical safety.
Manufacturer: approve scope, conformity conclusions, technical documentation, declaration, CE marking, production controls, and corrective action under each applicable act.
Importer and distributor: perform the checks and actions assigned by each directive; one compliant marking does not prove that every underlying act was assessed.
Change control: reassess both workstreams when the design, material, supplier, component, intended function, rated voltage, standard, or exemption status changes.
Articles 7 and 13 to 16 support RoHS technical documentation, internal production control, EU declaration, CE marking, ten-year retention, and presumption of conformity.
Supports the distinction between Low Voltage and RoHS as separate electric and electronic engineering standards areas.
Low Voltage (LVD)
Recommended next step
Separate LVD safety evidence from RoHS substance evidence
Build one CE evidence index that names every applicable Union act, then tag each declaration, standard, report, and supplier record to the claim it actually supports.
Current consolidated RoHS text for scope, definitions, restricted substances, homogeneous-material limits, exemptions, economic-operator duties, technical documentation, declaration, CE marking, and annex dates.
Articles 2 and 3 and Annex I support the RoHS EEE definition, upper voltage values, eleven product categories, and listed scope exclusions.
Article 3(20), Article 4, Article 5 and Annexes II to IV support the homogeneous-material test, ten restricted substances and maximum concentrations, and application-specific exemption system.
Show 11 more
Articles 7 and 13 to 16 support RoHS technical documentation, internal production control, EU declaration, CE marking, ten-year retention, and presumption of conformity.
Articles 2 and 3 and Annex I support the EEE scope, categories, upper voltage values, dependency test, and exclusions.
Article 4 and Annex II support the ten restricted substances, homogeneous-material basis, and maximum concentrations.
Articles 7 and 13 support manufacturer technical documentation, internal production control, declaration, and conformity responsibilities.
Articles 7 and 13 to 15 support RoHS technical documentation, internal production control, EU declaration, CE marking, ten-year retention, and use of a single technical documentation set where permitted.
Article 16 supports presumption of conformity for the RoHS requirements covered by applicable harmonised standards.
Article 2 and Annexes III and IV distinguish product exclusions from application-specific substance exemptions and their dates.
Articles 7, 9 and 10 support manufacturer, importer and distributor duties for non-conformity, records, information requests, and cooperation.
Supports separate RoHS product-scope, homogeneous-material, conformity-documentation, and exemption conclusions.
Articles 2 to 5 and Annexes I to IV support the RoHS scope, material-level restriction, and exemption decision sequence.
Supports RoHS scope, material-level restrictions, exemptions, technical documentation, declaration, CE marking, and change-control duties.
Supports LVD voltage scope, safety objectives, technical documentation, conformity assessment, EU declaration, CE marking, and multi-act declaration statements.
Supports LVD voltage scope, safety objectives, technical documentation, conformity assessment, EU declaration, and CE marking claims.
Supports LVD presumption of conformity and technical-documentation requirements for applied standards and alternative solutions.
Show 7 more
Supports the voltage bands and Annex II exclusion boundary.
Supports the LVD safety-objective statement.
Supports the LVD technical documentation content boundary.
Supports LVD EU declaration and CE marking requirements.
Supports LVD harmonised-standard presumption of conformity.
Supports the LVD evidence components in Annex III and Article 6.
Supports LVD voltage scope, safety evidence, and single EU declaration statements.
"electrical equipment designed for use within certain voltage limits"
More quoted passages
"between 50 and 1 000 V for alternating current and between 75 and 1 500 V for direct current"
"references of which have been published in the Official Journal of the European Union"
"other than the equipment and phenomena listed in Annex II"
"health and safety of persons and domestic animals, or property"
"include an adequate analysis and assessment of the risk(s)"
"draw up an EU declaration of conformity and affix the CE marking"
"presumed to be in conformity with the safety objectives"
"results of design calculations made, examinations carried out, etc.; and"
"That declaration shall contain the identification of the Union acts concerned"