Where to Start with CE, EMC, LVD and RoHS in Electronic Products ? -Part 3/3 LVD TEST

1. Introduction

CE marking in electronic products is often perceived merely as “having tests performed.” In reality, however, this process begins with understanding the correct directive, selecting the appropriate standards, and technically demonstrating safety.

In this third and final part of the series, we address—specifically within the scope of the Low Voltage Directive (LVD)—where tests are defined, how they are accepted, and what manufacturers are required to do in practice, all within a systematic framework. In the previous sections, we examined the general structure of CE marking and EMC requirements; in this part, we clarify how tests are determined under the LVD, the role of harmonized EN standards, and how conformity is demonstrated in practice.

2. What Is the LVD?

When not properly designed, electrical products can pose serious risks such as electric shock, overheating, fire, and mechanical hazards. To control these risks while ensuring the free movement of products within the EU internal market, the European Union introduced the Low Voltage Directive (LVD).

The Low Voltage Directive (2014/35/EU) is a binding EU regulation that requires electrical equipment operating within certain voltage limits to be safe for human health, animals, and property.

At this point, one critical clarification must be made: The LVD is not a test standard. The LVD does not define how a product should be tested; it defines the level of safety that must be achieved.

3. Scope of the LVD

The LVD applies to electrical equipment operating within the following voltage ranges:

50 – 1000 V AC
75 – 1500 V DC

These voltage values refer to the input or output voltage of the equipment. The presence of higher voltages inside the device does not change its inclusion within the scope of the LVD.

The LVD covers a very broad range of products, from household appliances to industrial equipment. Despite the term “low voltage,” the objective is to ensure the safety of all electrical products that carry a high potential risk.

4. Products Within Scope (Examples)

Examples of products evaluated under the LVD include:

Household appliances (washing machines, ovens, coffee machines)
Power supplies and adapters
Lighting luminaires and LED drivers
Electric motors
Cables, plugs, and sockets
Industrial control and power equipment

The common characteristic of these products is that they use, transmit, or convert electrical energy and can pose serious safety risks if improperly designed.

5. Products Outside the Scope (Annex II)

Not every electrical product falls within the scope of the LVD. Some products are explicitly excluded under Annex II, primarily because they are regulated by other EU directives.

Examples include:

Medical devices → MDR
Equipment for explosive atmospheres → ATEX
Radio equipment → RED
Lifts → Lifts Directive

Being outside the scope of the LVD does not mean that these products have no safety requirements; it simply means that they are subject to different directives.

Annex I (Safety Objectives): Defines the essential safety objectives that an electrical product must meet in order to be considered safe.

Annex II: Lists the products and situations that are excluded from the scope of the LVD.

Article 3: Stipulates that a product may be placed on the EU market only if it has been designed and manufactured in accordance with good engineering practice and does not endanger people, animals, or property under normal conditions of use.

You can review the directive in detail via the link below.

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0035

6. Components

One of the most frequently misunderstood topics within the scope of the LVD is the CE marking requirement for components.

Not every electronic component is required to carry a CE marking.

6.1 Basic Components That Do Not Require CE Marking

Components whose safety cannot be assessed on their own and which only gain meaning as part of a final product are not considered electrical equipment under the LVD:

Integrated circuits (ICs)
Diodes, transistors
Resistors, capacitors, inductors
Optocouplers

The safety of these components depends on the design and implementation of the final product; therefore, they do not carry a CE marking.

6.2 Components That Require CE Marking

Some components fall within the scope of the LVD because they present independently assessable risks:

Transformers
Electric motors
Power modules

These components require CE marking because they can independently create risks such as electric shock, overheating, and fire.

7. Essential Safety Requirements (Article 3 & Annex I)

The foundation of the LVD is Article 3 and Annex I. The Directive requires that electrical equipment be designed and manufactured in accordance with good engineering practice and that it does not pose a hazard under proper installation, maintenance, and foreseeable conditions of use.

These safety objectives form the technical rationale behind the tests defined in the selected EN standards.

8. Safety Objectives

The safety objectives defined in Annex I can be broadly grouped into three main categories:

8.1 Electrical Safety

Access to live parts must be prevented
Adequate insulation must be provided
The risk of electric shock must be eliminated

8.2 Thermal Safety

Overheating must be prevented
The risk of burning and fire must not be created

8.3 Mechanical and Physical Safety

Structural integrity must be ensured
The product must be safe against external influences

At this point, the LVD defines not “how to test,” but “the level of safety that must be achieved.”

9. Why Are Tests Not Defined in the LVD?

The question “Where are the LVD tests?” is frequently asked.

The answer is clear: tests are not defined in the LVD. This is because the LVD is a legal text, while test methods are the subject of technical standards.

For this reason, there is no legal concept of an “LVD test.” The correct expression is standard tests performed to demonstrate conformity with the LVD.

10. How Are Tests Defined and Accepted?

The LVD leaves the definition of tests to harmonized EN standards. The process follows these steps:

The product type is identified
The relevant EN standard is selected
The tests defined in the standard are applied
Compliance with the safety objectives defined in Annex I is presumed

This approach is known as Presumption of Conformity.

11. Standard Selection and Verification Approach Based on Product Type

Within the scope of the Low Voltage Directive, the first and most critical step in conformity assessment is correctly determining which family of standards applies to the product. This decision is not based on the commercial name or marketing description of the product, but on its main function, intended environment of use, and target user profile.

Once the product type has been determined, the appropriate EN standard that technically satisfies the safety objectives defined in Annex I is selected. The validity of these standards is verified through the harmonized standards list published by the European Commission.

11.1 Product – Standard – Verification Source Relationship

The mappings presented in this table show the most commonly used and inspection-accepted product–standard relationships within the scope of the LVD. Each standard defines technical requirements by considering the risks specific to its product group, including electrical safety, thermal risks, mechanical robustness, and foreseeable fault conditions.

11.2 Are Harmonized Standards Mandatory?

The application of harmonized EN standards is not legally mandatory. However, these standards provide manufacturers with a presumption of conformity and allow compliance with safety objectives to be accepted during inspections without the need for additional technical justification.

When harmonized standards are not applied, the manufacturer is required to demonstrate—through detailed technical documentation—that the alternative solutions provide an equivalent or higher level of safety.

12. Implementation of Tests and Technical Documentation

The LVD does not require mandatory involvement of a third party in the conformity assessment process. However, regardless of the chosen approach, the fundamental requirement remains the same: the safety objectives must be technically demonstrable.

12.1 Tests Performed by the Manufacturer

For tests performed by the manufacturer to be considered acceptable, the suitability of the test equipment, compliance of the test methods with the relevant EN standard, and traceable reporting of the results must be ensured. In this case, the entire burden of proof rests with the manufacturer.

12.2 Accredited Laboratory Tests

Reports issued by accredited laboratories provide fast and clear verification during inspections and market surveillance activities. This approach is particularly preferred for high-risk or complex products.

12.3 Technical File Content

Within the scope of the LVD, the technical file is not limited to test reports alone. The following elements must be included in a holistic manner:

Product description and intended use
Risk analysis and implemented risk control measures
List of applied EN standards
Test reports and calculations
User manual and safety instructions

This documentation must be structured in a way that demonstrates the product’s safety throughout its entire lifecycle.

13. Conclusion

The Low Voltage Directive aims to ensure that an electrical product remains safe not only under laboratory conditions, but also in real-world usage scenarios. For this reason, the LVD provides a holistic safety framework covering design, manufacturing, and the entire product lifecycle.

With this three-part series, my aim was to explain the rationale behind CE marking not by memorizing EMC, LVD, and RoHS as separate topics, but by showing how they should be addressed together from an engineering perspective. Viewing the CE process not as “tests performed at the end,” but as a systematic process that must be managed starting from the design phase forms the basis of this approach.

You are welcome to share your questions, different product scenarios, or your own experiences in the comments; let’s evaluate them together. Thank you for reading — I hope this series has been useful and enjoyable.