The Low Voltage Directive (LVD) aims to ensure the safety of electrical and electronic products with an input or output voltage within a certain range. Generally speaking, the Low Voltage Directive applies to devices and their power supply units that can be plugged into the power socket. Hence, it covers both consumer electronics and AC adapters.
In this guide, we explain what importers and manufacturers must know concerning the directive’s safety standards, labelling, documentation, and other requirements.
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What is the Low Voltage Directive?
The Low Voltage Directive establishes conditions to which importers and manufacturers must adhere, for the manufacture, import and sale of electrical and electronic equipment that operates at a certain voltage in the EU.
Specifically, it sets requirements that aim to ensure that the equipment is used safely and within its intended use, in order to protect the health and safety of:
- Consumers
- Domestic animals
- Property
Product Scope
The Low Voltage Directive covers electrical and electronic devices with an input or output voltage between 50 and 1,000 V for alternating current (AC), and 75 and 1,500 V for direct current (DC).
As such, many consumer electronic devices fall under the scope of the directive. Here are a few examples:
- AC adapters
- LED lighting
- Vacuum cleaners
- Electric ovens
- Cables
- Laser equipment
Note that certain electrical components (e.g., fuses and switches) are also covered by the directive if they are intended to be integrated into the final product.
AC Adapters
AC adapters must comply with the requirements outlined in the directive. However, this may not be the case for the connected device if the input voltage (which is the output voltage from the AC adapter) is below the threshold (e.g. 50 V).
That said, the directive may also apply to the product itself if it falls within the covered input or output voltage range.
Exempted Products
Annex II lists equipment and phenomena not covered by the directive, which includes the following products:
a. Electrical equipment for use in explosive atmospheres.
b. Electrical equipment for medical and radiology purposes.
c. Electrical parts for elevators.
d. Electricity meters.
e. Domestic plug and socket outlets.
f. Controllers for electric fences.
g. Radio-electrical interference.
h. Specialised electrical equipment for use on aircraft, railways, or ships.
i. Custom-built evaluation kits for professional research and development purposes.
Harmonised Standards
Harmonised standards are developed by organizations such as CEN and CENELEC. Importers and manufacturers should refer to relevant standards to ensure product compliance.
In this section, we list some harmonised standards under the Low Voltage Directive.
EN 60947 – Low-voltage switchgear and control gear
EN 60947 is an 8-part standard that sets rules, specific requirements, and safety specifications for low-voltage switchgear and control gear such as the following:
- Circuit breakers
- Switches and disconnectors
- Contactors and motor-starters
- Control circuit devices
- Transfer switching equipment
- Terminal blocks for copper conductors
- Control units for built-in thermal protection for rotating electrical machines
EN 61995 – Devices for the connection of luminaires for household and similar purposes
EN 61995 is a 2-part standard, the first of which covers general requirements, and the second of which contains standard sheets for devices for the connection of luminaires for household and similar purposes.
EN 61204 – Low-voltage power supply devices
EN 61204 specifies performance characteristics and requirements for low-voltage power supply devices. It also covers electromagnetic compatibility and safety requirements of low-voltage switch-mode power supplies.
The standard applies to items such as the following:
- Power supplies for general-purpose applications
- Rectifiers
- Converters
- Stabilised power supply
EN 61347 – Lamp control gear
EN 61347 is a 2-part standard that covers the general, safety, and particular requirements for lamp control gear. It applies to multiple products, such as the following:
a. Starting devices.
b. Ballasts for fluorescent lamps.
c. Miscellaneous electronic circuits used with luminaires.
Compliance Risks
Keep in mind that many electronic products manufactured outside the EU are not designed to comply with the relevant EN standards. Ensuring compliance requires that the manufacturer understands how to implement the EN standards on a hardware design level – which is a capability lacking among many smaller electronics factories located in Asia.
It’s therefore critical to first assess which EN standards apply to your product, and then verify said compliance through third-party testing.
General Requirements
Per Article 3 of the directive, importers and manufacturers may place electrical equipment on the EU market if those products:
a. Are constructed per good engineering practice.
b. Do not endanger the health and safety of consumers, pets, or property, when they are properly installed, maintained, and used in the ways for which they were manufactured.
General conditions
Article 3 references Annex I, which lists principal safety objectives for low-voltage electrical equipment. We summarise these objectives below.
a. The electrical equipment must be marked with its essential characteristics to ensure its safe and intended usage. If it is impossible to mark the equipment, an accompanying document must provide this information instead.
b. The equipment and its component parts must be manufactured to ensure that it can be properly and safely assembled and connected.
c. The electrical equipment’s design and manufacture must be such that it is protected against hazards that:
- May arise from the product
- May be caused by external influences on the product
Conformity Assessment
Importers and manufacturers should comply with the conformity assessment procedure (Module A – Internal production control) set in Annex III, by fulfilling obligations regarding:
- Technical documentation
- Manufacturing
- CE marking
- Declaration of Conformity
The conformity assessment does not require the services of a notified body.
Documentation
In this section, we explain the required documents including the Declaration of Conformity (DoC), user instructions, technical file, and test reports.
Declaration of Conformity (DoC)
The DoC is a self-issued document that “declares” that the product identified in the DoC complies with the directive’s requirements, such as testing, labelling, and documentation.
It is also the primary document that demonstrates compliance upon request from government bodies, authorised organizations, and retailers.
Per Annex IV of the directive, the DoC must contain the following information:
a. Product model and batch, type, or serial number.
b. Manufacturer’s name and address.
c. The statement “This declaration of conformity is issued under the sole responsibility of the manufacturer.”
d. Product traceability information – may include a colour photograph.
e. List of harmonisation legislation for which the product object of this DoC complies.
f. References to applicable and utilised harmonised standards, or to other technical specifications.
g. The date and place where the DoC was issued.
h. Signature, name and function of the manufacturer.
Technical Documentation
The manufacturer must provide the technical documentation, which should allow an assessment of the electrical equipment’s conformity to applicable requirements, and should include a risk analysis.
The technical documentation must also specify relevant requirements and cover the electrical equipment’s design, manufacture, and operation. It should include information such as the following:
a. An overall description of the electrical product.
b. Concept design, and manufacturing drawings and schematics of items such as parts, sub-assemblies, and circuits.
c. Explanations of the electrical product’s drawings, schematics, and operation.
d. A list of harmonised standards used (if none were utilised, the manufacturer may describe compliance solutions, and include a list of applicable technical specifications).
e. Outcomes of items such as design calculations and examinations; and
f. Test reports.
User Instructions
User instructions must accompany electrical products covered by the directive. Manufacturers must ensure, before placing electrical equipment on the market, that the instructions are:
a. Written in a language easily understood by end-users and consumers in the relevant EU member states; and
b. Clear, straightforward, and comprehensible.
Manufacturers must also ensure that safety information is provided with the electrical equipment.
Test Report
The Low Voltage Directive compliance depends mostly on compliance with specific EN standards.
Therefore, it is important for importers and manufacturers to conduct relevant lab tests and obtain the necessary test reports. Additionally, the conformity assessment requires manufacturers to include test reports as part of their technical documentation.
Labelling Requirements
Importers and manufacturers must ensure that any labelling that accompanies the electrical equipment must be readable, comprehensible, and clear.
CE Marking
The CE marking indicates the conformity of the electrical equipment to relevant requirements. Article 17 of the directive specifies rules and conditions for affixing the CE marking onto electrical equipment:
a. The CE marking must be affixed to the product or its data plate in such a manner that it is easily seen, readable, and permanent. If doing so is impossible (e.g., because of the product’s nature), then the product’s packaging and accompanying documents must bear it instead.
b. The CE marking must be affixed before importers and manufacturers place the product on the market.
Product Traceability
Importers and manufacturers must affix permanent traceability information on the product. When it’s impossible to affix such information on the product itself, they must affix the information on the packaging or in the documentation accompanying the product – for instance, the user instructions.
This information must include:
a. The importer’s or manufacturer’s names, registered trade names or registered trademark names.
b. The importer’s or manufacturer’s postal addresses where they can be contacted.
c. The electrical equipment’s type, batch, or serial number.
Importers and manufacturers must ensure that the information is provided in a language easily understood by both the final user and the relevant authorities.
Lab Testing
Importers and manufacturers must ensure that their products comply with relevant requirements. In practice, this means they often need to have their products lab tested per the technical requirements of the directive.
When their product passes testing, they receive a test report that proves compliance with such requirements.
Test methods
Here, we list several test methods that might be relevant for products covered by the Low Voltage Directive:
a. Electrical, and non-electrical, test methods for low-voltage energy cables.
b. Glow-wire flammability test method for end-products.
c. Test methods for surge protective devices that are connected to low-voltage power systems.
d. Test methods for measuring the thickness of insulation for non-metallic materials
Lab test companies
Here are a few lab test companies that offer to test to the Low Voltage Directive’s requirements:
FAQ
How do I know if the Low Voltage Directive applies to my product?
The Low Voltage Directive applies to electrical equipment with an input or output voltage of between
- 50 and 1000 V for AC, and
- 75 and 1500 V DC
As such, the Low Voltage Directive is applicable to most products plugged directly into the power socket.
Keep in mind that the Low Voltage Directive is also applicable to AC adapters and chargers that come with most consumer electronics, such as phones, tablets, and other devices.
How do I know which EN standards apply?
You can download a list of harmonised standards from the official EU Commission website. Here are some examples:
- EN 50117
- EN 50250
- EN 50525
- EN 60669
How do I know if a product on Alibaba complies with the Low Voltage Directive?
You should contact your supplier and request a lab test report to determine whether your product is compliant with the Low Voltage Directive. However, few suppliers can provide complete and up-to-date (e.g. current harmonised standards) Low Voltage Directive lab test reports for all products.
As such, you will likely need to order product samples and send them to a third-party testing company.
Note that this applies to power supply units, in addition to electronic devices.
How much does Low Voltage Directive testing cost?
Testing costs might range from USD 1,000 to 3,000 per product. Ultimately it depends on the number of applicable standards.
You can contact different lab testing companies and request a quote regarding the cost of having your products tested according to the requirements in the Low Voltage Directive.
This is an excellent article and provided me with a good basic understanding of the directive. Unfortunately I have come across many manufacturers that Mark their product with the CE mark but will not provide technical documents when asked as the directive describes