LVD low voltage command

In order to adapt to the New Legislative Framework (NLF) of the European Union, on March 29, 2014, the official journal of the EU published a new version of the Low Voltage Directive 2014/35/EU to replace the original Low Voltage Directive 2006/95/EC.

The new directive will be implemented from April 20, 2016. Each member state must complete the legislative process by April 19, 2016. In other words, products that comply with the old low voltage directive will not be accepted after April 20, 2016.

The new directive aims to ensure easier market access and higher levels of protection for consumer life and property:

1. Clarify the responsibilities of manufacturers, importers, and distributors;

2. The wider application of electronic means in compliance proof;

Through the improvement of defect or unsafe and product traceability systems, and the continuous improvement of the system and supervision of qualification assessment institutions, consumer safety is more guaranteed;

4. More comprehensive market supervision agencies to track and prevent the import of dangerous products;

What is the range of Q1 low voltage command?

Suitable for electrical products designed with rated voltages ranging from AC 50~1000 volts and DC 75~1500 volts, except for the following products:

a. Electrical products used in explosive environments

b. Electrical products used for radiation or medical purposes

c. Electrical components of freight or passenger elevators

d. Electric meter

e. Household plugs and sockets

f. Controller for electric fence

g. Radio interference

h. Specialized electrical products used in ships, aircraft, or railways that comply with safety regulations established by international organizations involving EU member states

i. Customized evaluation equipment used by professionals solely for research and development purposes in research and development facilities

What is the scope of low voltage directive?

Shall apply to electrical equipment designed for use with a voltage rating of between 50 and 1 000 V for alternating current and between 75 and 1 500 V for direct current, other than those listed below:

a. Electrical equipment for use in an explosive atmosphere

b. Electrical equipment for radiology and medical purposes

c. Electrical parts for goods and passenger lifts

d. Electricity meters

e. Plugs and socket outlets for domestic use

f. Electric fence controllers

g. Radio-electrical interference

h. Specialised electrical equipment, for use on ships, aircraft or railways, which complies with the safety provisions drawn up by international bodies in which the Member States participate.

i. Custom built evaluation kits destined for professionals to be used solely at research and development facilities for such purposes.

Q2. What are the main changes in the new low voltage command compared to the old command?

1) The new definition in Article 2 is derived from R1 in Appendix I of 768/2008/EC;

2) The new requirements for the obligations of economic operators in Articles 6-11 are derived from R2~R7 in Appendix I of 768/2008/EC;

3) The more specific principles regarding CE marking in Article 16 are derived from Article 30 of (EC) 765.2008;

4) More specific requirements regarding market regulation, Article 18, derived from Article 15 point 3, Articles 16-29 of (EC) 765.2008; Articles 19-22, derived from R31~R34 in Appendix I of 768/2008/EC;

5) The newly added exemption clause in Appendix II states that "customized evaluation equipment used by professionals solely for research and development purposes in research and development facilities";

6) The additional requirement for preparing technical documents in Appendix III, 'Adequate analysis and assessment of risks', is derived from point 2 of Appendix II of 768/2008/EC;

7) Removed the requirement for EU notified bodies to provide support in points 2, 3, and 11 of the old directive.

What is the main change of the new low voltage directive comparing with the old directive?

1) New definitions in article 2 - from 768/2008/EC Annex I R1;

2) New requirement of the obligations of economic operators in Article 6~11 - from 768/2008/EC Annex I R2~R7;

3) More detailed principle of CE marking in article 16 – from (EC)765.2008 Article 30;

4) More detailed requirement of market surveillance in Article 18 - from (EC)765/2008 Article 15(3), Article 16~29;  Article 19~ 22 – from 768/2008/EC Annex I R31~ R34;

5) New exemption item in Annex II:  “Custom built evaluation kits destined for professionals to be used solely at research and development facilities for such purposes”;

6) Additional requirement of preparation of technical documentation for “adequate analysis and assessment of the risk(s)” in Annex III – from 768/2008/EC Annex II point 2;

7) Delete the requirement of support from notified body in Article 8(2), 8(3), and11 in old directive.

Q3. What are the safety objectives of low voltage commands?

Electrical products, when installed, maintained, and used correctly according to their intended use, must not endanger the health and safety of humans and domestic animals, or endanger property.

What is the safety objective of low voltage directive?

Electrical equipment does not endanger the health and safety of persons and domestic animals, or property, when properly installed and maintained and used in applications for which it was made.

Q4. How to identify products, manufacturers, and importers?

1) Manufacturers should ensure that the product is labeled with the model, batch or serial number or other identifiable elements, or if not possible, on the packaging or accompanying documents;

2) Manufacturers should display their name, registered trademark name or logo, and postal address on the product, or if not possible, on the packaging or accompanying documents. The address should be a single location;

3) Importers should display their name, registered trademark name or logo, and postal address on the product, or if not possible, on the packaging or accompanying documents.

How to identify the product, manufacturer and importer?

1) Manufacturers shall ensure product bears a type,  batch or serial number or other element for identification or not possible, on the packaging or accompanying document ;

2) Manufacturers shall indicate manufacturer’s name,  registered trade name or trade mark and postal address on the product, or not possible, on the packaging or accompanying document. The address shall indicate a single point;

3) Importer shall indicate importer’s name,  registered trade name or trade mark and postal address on the product, or not possible, on the packaging or accompanying document.

Q5. How to comply with the low voltage command?

Through the manufacturer's compliance assessment process: Internal Production Control (Mode A)

1) Prepare technical documents that include sufficient risk analysis and assessment;

2) The manufacturing process and its supervision should ensure that the manufactured products comply with the provisions of the technical documents;

3) Draft the EU Declaration of Conformity (DoC);

4) Post CE marking.

How to comply with the low voltage directive?

By conformity assessment procedure: Internal production control (module A) by manufacturers

1) Technical documentation which includes an adequate analysis and assessment of the risk(s);

2) Manufacturing process and its monitoring shall ensure compliance of the manufactured product with the technical documentation;

3) Drawing up of EU declaration of conformity (DoC);

4) Affixing of CE marking.

Q6. What should be included in the "technical documents"?

1) Adequate risk analysis and assessment;

2) Overall description of electrical products;

3) Design concept and manufacturing drawings, as well as details of components and assemblies;

4) To understand the necessary descriptions and explanations required for the corresponding drawings and details, as well as the work of electrical products;

5) A list of coordinated standards, international standards, or national standards that are fully or partially applied, as well as a description of the solutions adopted to meet the safety objectives of the directive in the absence of coordinated standards, international standards, or national standards, including a list of other relevant technical specifications applied. If coordinated standards, international standards, or national standards are partially applied, the technical documents should indicate the part applied;

6) The results of design calculations and inspections made;

7) Testing report.

What shall be included in “Technical documentation”?

1) An adequate analysis and assessment of the risk(s);

2) A general description of the electrical equipment;

3) Conceptual design and manufacturing drawings and schemes of components,  sub-assemblies, circuits, etc.;

4) Descriptions and explanations necessary for the understanding of those drawings and schemes and the operation of the electrical equipment;

5) A list of the harmonised standards applied in full or in part or international or national standards and,  where those harmonised standards or international or national standards have not been applied, descriptions of the solutions adopted to meet the safety objectives of this Directive, including a list of other relevant technical specifications applied. In the event of partly applied harmonised standards or international or national standards, the technical documentation shall specify the parts which have been applied;

6) Results of design calculations made,  examinations carried out, etc.;

7) Test reports.

Q7. How to do "risk analysis and assessment"?

1) Manufacturers should be responsible for establishing correct risk assessments (procedures and documents);

2) Manufacturers can refer to the risk assessment techniques or other applicable methods for risk management mentioned in EN31010:2010 (IEC/ISO 31010:2009); ISO/TR 14121-2 guides manufacturers to use group collaboration schemes in risk analysis and assessment;

3) Manufacturers should maintain documented evidence demonstrating compliance with Appendix I (Elements of Safety Objectives);

4) If manufacturers cannot provide risk assessment information to market regulatory agencies, it will result in corresponding penalties.

What to do for the “analysis and assessment of the risk”?

1) Manufacturer is responsible that the risk assessment (test procedure and document) is established in the right way;

2) Manufacturer may refer to the risk assessment techniques for risk management described in EN 31010:2010 (IEC/ISO 31010:2009) or other applicable method;  ISO/TR 14121-2 guides the manufacturer may use the team approach for risk analysis and assessment;

3) Manufacturer shall have documented evidence that Annex I (principal elements of the safety objectives) is fulfilled;

4) If manufacturer can’t provide a risk assessment to the market authorities,  penalties are possible.