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.
RoHS may still be a separate CE workstream for electrical and electronic products because the LVD Guide names the Restriction of Hazardous Substances Directive as another EU act that can apply alongside LVD.
Structured answer sets in this page tree.
Cited legal and guidance references.
LVD and RoHS should not be treated as interchangeable labels in a CE file. The LVD side asks whether electrical equipment within the LVD voltage limits meets safety objectives and has the LVD technical documentation, conformity assessment, EU declaration, and CE marking evidence. The RoHS side is only addressed here at the LVD-grounded boundary: it is a separate EU act concerning restriction of hazardous substances that can apply to electrical and electronic equipment.
A narrow comparison of LVD and RoHS where the LVD source set supports the boundary: electrical safety, hazardous-substance restriction, CE file overlap, declarations, standards, and documentation limits.
Electrical equipment safety regime for products within 50-1000 V AC or 75-1500 V DC, subject to LVD exclusions.
Separate EU act named in LVD guidance and Commission standards materials as the restriction-of-hazardous-substances workstream for electrical and electronic equipment.
| Dimension | LVD | RoHS | Operational implication |
|---|---|---|---|
| Scope boundary | 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. | The LVD source set supports only a high-level RoHS boundary: it is a separate electric and electronic engineering area and may apply alongside LVD. | Record the LVD voltage and exclusion analysis separately from any RoHS scoping record. |
| Covered actors | LVD addresses safety objectives for electrical equipment: health and safety of persons and domestic animals, and protection of property. | RoHS is treated here only as the separate hazardous-substance restriction workstream that may also apply to electrical and electronic products. | Use LVD for safety evidence and RoHS for substance-control evidence; do not swap one for the other. |
| Trigger | LVD technical documentation must allow assessment of conformity, include an adequate risk analysis and assessment, and cover design, manufacture, and operation as relevant. | RoHS documentation may be indexed beside LVD evidence, but this LVD-only source set does not support detailed RoHS documentation contents. | Use one evidence index if helpful, but label each item by legal act and do not let the LVD technical file stand in for a RoHS file. |
| Core obligations | LVD requires the manufacturer to draw up an EU declaration of conformity and affix CE marking after LVD conformity is demonstrated. | Where RoHS is also an applicable Union act requiring an EU declaration, LVD Article 15 supports using a single declaration that identifies each Union act and publication reference. | A combined declaration can reduce paperwork, but each listed act still needs its own supporting evidence. |
| Evidence record | 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 appears as a separate standards area in the Commission overview, so RoHS standards evidence should be tracked separately from LVD safety standards evidence. | Keep the standards table explicit so each row shows the legal act, the publication basis, and the file section it supports. |
| Timing and deadlines | LVD evidence should prove the electrical safety conclusion: safety objectives, applied standards, design/manufacturing assessment, examinations, test reports, declaration, and CE marking. | RoHS evidence should not be inferred from LVD safety evidence in this artifact; this source set supports only the fact that RoHS can be a separate applicable act. | Separate the file chronology as well: keep LVD technical documentation and RoHS substance records in their own dated evidence chains, even if they sit in one index. |
| Enforcement | LVD addresses safety objectives for electrical equipment: health and safety of persons and domestic animals, and protection of property. | RoHS is treated here only as the separate hazardous-substance restriction workstream that may also apply to electrical and electronic products. | 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 technical evidence can be reused across products only when the same voltage scope, safety objective, and applied standard basis still match. | RoHS evidence may share the same file index, but it must still be supported by its own substance-control basis and not by LVD safety testing alone. | Share the container, not the conclusion: one index can hold both workstreams, but each workstream needs its own support line. |
| Practical decision rule | 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. | RoHS applies when the product is electrical and electronic equipment in a separate hazardous-substance scope; the LVD source set here only supports naming that workstream, not detailing it. | Decide first which legal act each document supports, then build the file around that act instead of asking one act to prove the other. |
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.
The LVD source set supports only a high-level RoHS boundary: it is a separate electric and electronic engineering area and may apply alongside LVD.
Record the LVD voltage and exclusion analysis separately from any RoHS scoping record.
LVD addresses safety objectives for electrical equipment: health and safety of persons and domestic animals, and protection of property.
RoHS is treated here only as the separate hazardous-substance restriction workstream that may also apply to electrical and electronic products.
Use LVD for safety evidence and RoHS for substance-control evidence; do not swap one for the other.
LVD technical documentation must allow assessment of conformity, include an adequate risk analysis and assessment, and cover design, manufacture, and operation as relevant.
RoHS documentation may be indexed beside LVD evidence, but this LVD-only source set does not support detailed RoHS documentation contents.
Use one evidence index if helpful, but label each item by legal act and do not let the LVD technical file stand in for a RoHS file.
LVD requires the manufacturer to draw up an EU declaration of conformity and affix CE marking after LVD conformity is demonstrated.
Where RoHS is also an applicable Union act requiring an EU declaration, LVD Article 15 supports using a single declaration that identifies each Union act and publication reference.
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 appears as a separate standards area in the Commission overview, so RoHS standards evidence should be tracked separately from LVD safety standards evidence.
Keep the standards table explicit so each row shows the legal act, the publication basis, and the file section it supports.
LVD evidence should prove the electrical safety conclusion: safety objectives, applied standards, design/manufacturing assessment, examinations, test reports, declaration, and CE marking.
RoHS evidence should not be inferred from LVD safety evidence in this artifact; this source set supports only the fact that RoHS can be a separate applicable act.
Separate the file chronology as well: keep LVD technical documentation and RoHS substance records in their own dated evidence chains, even if they sit in one index.
LVD addresses safety objectives for electrical equipment: health and safety of persons and domestic animals, and protection of property.
RoHS is treated here only as the separate hazardous-substance restriction workstream that may also apply to electrical and electronic products.
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 technical evidence can be reused across products only when the same voltage scope, safety objective, and applied standard basis still match.
RoHS evidence may share the same file index, but it must still be supported by its own substance-control basis and not by LVD safety testing alone.
Share the container, not the conclusion: one index can hold both workstreams, but each workstream needs its own support line.
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.
RoHS applies when the product is electrical and electronic equipment in a separate hazardous-substance scope; the LVD source set here only supports naming that workstream, not detailing it.
Decide first which legal act each document supports, then build the file around that act instead of asking one act to prove the other.
The LVD Guide states that other EU acts may also apply to electrical equipment within LVD scope, including the EMC Directive and the Restriction of Hazardous Substances (RoHS) Directive. The Commission harmonised standards overview also lists Low Voltage and RoHS as separate electric and electronic engineering subject areas.
That support is enough to compare the compliance boundary, but not enough to publish detailed RoHS article-level requirements from this LVD-only source folder.
A product can need one release file that references more than one Union act, but the evidence inside that file should stay traceable to the act it supports. Under LVD, the manufacturer must draw up technical documentation, carry out the Annex III conformity assessment procedure, draw up an EU declaration of conformity, affix CE marking, and keep the technical documentation and EU declaration for 10 years after the electrical equipment is placed on the market.
Where more than one Union act requires an EU declaration of conformity, LVD Article 15 allows a single EU declaration for all those acts, provided the declaration identifies the Union acts concerned and their publication references. That creates declaration overlap; it does not make the LVD risk assessment, standards list, test reports, or safety evidence prove RoHS compliance.
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.
LVD presumption of conformity is tied to harmonised standards, or parts of harmonised standards, whose references have been published in the Official Journal and that cover the relevant LVD safety objectives. The LVD technical documentation must identify the standards applied in full or in part, or describe the solutions used to meet the LVD safety objectives where those standards are not applied.
The Commission standards overview places LVD and RoHS in the same broad electric and electronic engineering standards area, but as separate entries. For comparison purposes, that means a standards tracker can sit in one CE file, while each entry still needs the correct legal basis and documentation purpose.
"Union harmonisation legislation"
"That declaration shall contain the identification of the Union acts concerned"
"Restriction of the use of certain hazardous substances (RoHS)"
"Low voltage (LVD)"