ComparisonEU product law

RED vs LVD electrical safety boundary

Use RED Article 3(1)(a) for the safety of radio equipment. It incorporates the LVD safety objectives but applies them without the LVD voltage limits.

Use the LVD independently for electrical equipment outside the RED product boundary, including a separately marketed power supply when it meets LVD scope.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
3

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

A battery-powered or extra-low-voltage radio product still needs RED safety evidence. Directive 2014/53/EU Article 3(1)(a) applies the safety objectives of Directive 2014/35/EU without any voltage limit, and Article 1(4) prevents separate LVD application to in RED scope. The LVD remains the independent route for electrical equipment designed for 50-1000 V AC or 75-1500 V DC when that equipment is outside the RED boundary and is not excluded by the LVD.

Side-by-side comparison

RED vs Low Voltage Directive

RED incorporates the LVD safety objectives for without voltage limits. LVD applies independently to qualifying electrical equipment outside that radio-product boundary.

Review all sources
First framework
Radio Equipment Directive 2014/53/EU

The legal route for , including health and safety under Article 3(1)(a), EMC, spectrum, conformity assessment, technical documentation, declaration, and CE marking.

Second framework
Low Voltage Directive 2014/35/EU

The legal route for electrical equipment within its voltage limits when it applies independently and no listed exclusion controls.

Comparison row 1

Scope

Radio Equipment Directive 2014/53/EU

A finished product that intentionally emits or receives radio waves for radio communication or radiodetermination.

Low Voltage Directive 2014/35/EU

Electrical equipment rated for 50-1000 V AC or 75-1500 V DC, subject to LVD exclusions.

Operational implication

Classify the item, not the test report or component certificate.

Comparison row 2

Safety rule

Radio Equipment Directive 2014/53/EU

RED applies the LVD safety objectives to with no voltage limit.

Low Voltage Directive 2014/35/EU

LVD applies its Annex I safety objectives only within its voltage and product scope.

Operational implication

Battery and extra-low-voltage still needs Article 3(1)(a) evidence.

Comparison row 3

Can both apply to one radio product?

Radio Equipment Directive 2014/53/EU

in RED scope is not separately subject to the LVD.

Low Voltage Directive 2014/35/EU

LVD can apply to a different, separately marketed electrical item, such as an in-scope external power supply.

Operational implication

Keep separate declarations only for separate product boundaries.

Comparison row 4

Evidence

Radio Equipment Directive 2014/53/EU

Final-product risk analysis, safety standards, test reports, charger and battery conditions, supplier evidence, instructions, declaration, and RED technical documentation.

Low Voltage Directive 2014/35/EU

Equivalent LVD evidence for the separate electrical item, including its design, tests, instructions, declaration, and technical documentation.

Operational implication

A supplier report supports but does not replace the final-product assessment.

Comparison row 5

Decision rule

Radio Equipment Directive 2014/53/EU

Use RED for the finished radio product and cite Article 3(1)(a) for safety.

Low Voltage Directive 2014/35/EU

Use LVD for a qualifying non-radio electrical item outside the RED boundary.

Operational implication

Match each declaration, standard, test report, and label to its actual product.

Practical decision rule

Which route should the team use?

  • Use RED Article 3(1)(a) for the finished , regardless of voltage.
  • Use LVD for a separately marketed, in-scope non-radio electrical product.
  • Verify final-system hazards instead of relying only on a charger, battery, or module certificate.
Section 1

Choose RED or LVD from the item being placed on the market

RED covers a finished electrical or electronic product that intentionally emits or receives radio waves for radio communication or radiodetermination. For that , 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.

  • Use RED for the finished radio product and map electrical-safety evidence to Article 3(1)(a).
  • Use LVD for a separately assessed non-radio electrical product within the LVD voltage range and outside its exclusions.
  • Do not cite both RED and LVD for the same safety claim on the same finished .
Section 2

Assess accessories and power supplies on their own boundaries

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.

  • Keep the separately marketed power supply's LVD declaration and reports as supplier evidence.
  • Keep final-product safety risk analysis, standards, test reports, charging conditions, accessories, instructions, and deviations in the RED technical file.
  • Reopen the assessment when the power architecture, battery, charger, enclosure, materials, firmware-controlled charging, or supplied accessories change.
Section 3

Prepare the right evidence and declaration

For , 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.

  • List the safety standard under the legal act and essential requirement it supports.
  • Explain any reliance on a power-supply, battery, module, or component certificate and verify the conditions of use.
  • Make the declaration, labels, instructions, test configuration, and technical file describe the same finished item.
Recommended next step

Map the radio product and separate electrical items

Connect each safety report, supplier declaration, charger, battery, and accessory to the correct product boundary and legal requirement.

Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Binding RED safety and non-duplication source.
eur-lex.europa.eu
Referenced sections
  • Articles 10 and 17-19 and Annexes II and V cover RED manufacturer duties, internal production control, declaration, CE marking, documentation, and retention.
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