RED vs LVD electrical safety boundary

RED covers a finished electrical or electronic product that intentionally emits or receives radio waves for radio communication or radiodetermination. For that radio equipment, Article 3(1)(a) requires protection of health and safety of persons and domestic animals and protection of property. It incorporates the LVD safety objectives, but no voltage limit applies.

The LVD applies independently to electrical equipment designed for use with a voltage rating between 50 and 1000 V AC or between 75 and 1500 V DC, subject to its listed exclusions. Annex II excludes, among other categories, electrical equipment for explosive atmospheres, radiology and medical purposes, parts for goods and passenger lifts, electricity meters, electric fence controllers, and ordinary domestic plugs and socket outlets. Another Union act can govern an excluded product.

A low-voltage radio device does not fall outside safety regulation merely because its internal or input voltage is below those LVD thresholds; RED removes the voltage threshold for the radio-equipment safety requirement. Representative examples include a battery-powered Bluetooth sensor, Wi-Fi camera, radio toy, or wearable: the finished radio product still needs a RED Article 3(1)(a) safety case.

An external mains power supply sold as its own product can have an LVD conformity file if it falls within the LVD scope. Its supplier declaration and test report are useful inputs to the radio-product assessment, but they do not discharge the radio-equipment manufacturer's responsibility for hazards created by the complete system.

Integration can change accessible temperatures, fire and energy hazards, charging behavior, mechanical stability, insulation, creepage and clearance, foreseeable misuse, enclosure access, battery conditions, and user instructions. Record whether the adapter, charger, battery, antenna, cable, or accessory is included, optional, or specified for use, and test the final configuration where those facts affect safety.

A radio module, battery certificate, or adapter declaration covers only its stated item and conditions. The company placing the finished radio product on the market must verify the host enclosure, accessible parts, power limits, thermal behavior, charging controls, foreseeable combinations, and instructions under RED.

For radio equipment, use the RED conformity route. The manufacturer may use internal production control for the Article 3(1) safety and EMC requirements; RED notified-body involvement is not automatically required merely because LVD-style safety evidence is used. Other RED requirements and the extent to which harmonised standards are applied can affect the overall conformity route.

The RED file should identify the product, applicable Article 3 requirements, safety standards or other technical specifications, design calculations, risk analysis, test reports, supplier evidence, instructions, EU declaration, and CE-marking basis. Keep the RED technical documentation and declaration for 10 years after placing the product on the market. A separate LVD product needs its own LVD technical documentation and declaration on its own boundary.