10 Commonly Asked Questions about the Low Voltage Directive
By Joseph Janeliunas
TÜV Product Service Inc. (Danvers, MA)
While many publications and manuals outline the LVD in detail, the focus of this article is to answer many of the practical questions manufacturers ask about the directive.
1. What electrical equipment is covered by the LVD?
With the exception of the equipment listed in Annex II, the directive applies to electrical equipment designed for use at a rated voltage of 50 to 1000 V for alternating current and 75 to 1500 V for direct current. Rated voltage refers to the input or output voltage of the equipment, and not voltages which are generated internally.
2. Can I complete LVD CE marking testing myself, or must I use a third party?
A CE marking according to the LVD is a manufacturer's self declaration of conformity. The manufacturer is obligated by law to be able to support its claim with proof that the product meets the essential health and safety requirements of the directive. This test data can be obtained from a third party, or manufacturers can provide it themselves.
3. Are "components" required to be CE marked?
Passive components (i.e. resistors, relays, connectors, etc.) are NOT required to be CE marked under the LVD because their safety depends on how they are integrated into the final product. According to the Guidelines on the Application of Council Directive 73/23/EEC, these components should NOT be CE marked. However, other components for which a safety assessment is feasible (motors and transformers) are covered by the directive and must be CE marked.
Because manufacturers of complete products want the components they use to be compliant with the applicable regulations, they often ask their suppliers for products with a CE marking, regardless of the type of component. It is important that manufacturers understand that simple components must meet the applicable requirements. However, because their compliance is installation dependent, they cannot be CE marked.
4. If components in your product are CE marked, do you need additional testing?
The end product must meet the requirements of the LVD and other applicable directives. The compliance of individual components with the requirements of appropriate European Norms (EN) does not imply compliance of the end product. End product testing ensures that interconnections as well as manufactured CE marked components are performing to what is formally stated in their declaration of conformity.
5. Who affixes the CE mark, and where is it affixed?
The CE mark is placed by the manufacturer or his authorized representative established in the Community. The CE mark is placed on the electrical equipment, or if that is not feasible, on the packaging, the instructions for use, or the guarantee.
See Guidelines on the Application of Council Directive 73/23/ EEC.
6. If peripheral products are CE marked, what rules apply to the whole unit?
The end product must meet the requirements of the appropriate CE marking directive(s). Because peripheral products meet the requirements and are CE marked, it does not mean that the whole unit will meet the CE marking requirements.
End product testing ensures that the interconnections as well as the CE marked components comply with what is stated in the Declaration of Conformity for the complete product.
7. What products are excluded from the LVD?
Electrical equipment for use in an explosive atmosphere.
Electrical equipment for radiology and medical purposes.
Electrical parts for goods and passenger lifts.
Plug and socket outlets for domestic use.
Electric fence controllers.
Radio-electrical interference apparatus.
Specialized electrical equipment, for use on ships, aircraft or railways, which complies with the safety provisions drawn up by international bodies in which the member state participates.
8. When did the grace period end for CE marking according to the LVD?
CE marking according to the LVD became mandatory on January 1, 1997.
9. Where can you keep a technical documentation file?
For the LVD, the technical documentation must be kept within the EU by the manufacturer or their authorized representative established in the Community.
10. How long must you keep the technical documentation?
Technical documentation files must be kept for at least ten years after the last manufacture date of the product.
The Low Voltage Directive harmonized electrical safety requirements in the EU, bringing safer, better-built products to the marketplace. The intent of this article has been to answer some common questions about the directive, but the article should not be regarded as a guide for establishing compliance. If your firm is interested in selling a product in the European Union, it is suggested that you seek the assistance of a notified or competent body to help you gain complete understanding of the LVD, and any other directives that may apply.