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10 Commonly Asked Question About the Low Voltage Directive
By: Joe Janeliunas - Sr. Manager, Compliance Services, TÜV Product ServiceThe Low Voltage Directive 73/23/EEC (LVD) was adopted by the European Council on February 19, 1973 with the purpose of harmonizing the laws of Member States relating to electrical equipment designed for use within certain voltage limits. In 1993, the LVD was amended by Directive 93/68/EEC to include the procedures for conformity assessment and CE marking products. CE marking of products that fall under the scope of the Low Voltage Directive is mandatory, and indicates compliance with the requirements of the European Union (EU).
Many publications and manuals outline the Low Voltage Directive in detail. The focus of this article however, is to outline many of the practical questions manufacturers ask regarding the Low Voltage Directive.
Q1: What electrical equipment is covered by the Low Voltage Directive?
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.
Q2: Can I complete LVD CE marking testing myself, or must I use a 3rd party?
A CE marking according to the Low Voltage Directive is a manufacturer's self declaration of conformity. The manufacturer is obligated by law to be able to support their 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.
Q3: Are "components" required
to be CE marked?
Passive components (i.e. resistors, relays, connectors, etc.) are NOT required to be CE marked under the Low Voltage Directive 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.
Q4: If components in your product
are CE marked, do you need additional testing?
The end product must meet the requirements of the Low Voltage 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.
Q5: Who affixes the CE marking, and where
is it affixed?
The CE marking is placed by the manufacturer or his authorized representative established in the Community. The CE marking 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.
Q6: 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 interconnection as well as CE marked components comply with what is stated in the Declaration of Conformity for the complete product.
Q7: What products are excluded from the Low Voltage Directive ?
Q8: When did the grace period end for CE marking according to the Low Voltage Directive?
CE marking according to the LVD became mandatory on 1-1-1997.
Q9: Where can you keep a technical documentation
For the Low Voltage Directive, the technical documentation must be kept within the European Union by the manufacturer or their authorized representative established in the Community.
Q10: How long do you need to 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 European Union (EU), bringing safer, better
built products to the marketplace. The intent of this article is to
answer some common questions about the directive, but 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 Low Voltage Directive, and any other Directives
that may apply