The Low Voltage Directive 73/23/EEC is one a series of measures introduced under article 100a of the Treaty of Rome. Article 100a directives all have the primary objective of creating a single European market in goods and services with the objective of providing producers and consumers with the benefits of economies of scale that this offers. The directive was originally enacted in 1973 but was modified in 1993 by directive 93/68/EEC to include a requirement for CE marking and the creation of a technical file.
The effect of the directive has been to introduce identical requirements for the safety of electrical products in every country within the European Economic Area (EEA).
Scope
The Directive applies to all apparatus operating on any AC supply between 50 and 1000 volts or DC supply between 75 and 1000 volts. Recent guidance from the European Commission has made it clear that the voltage limits referred to are the supply voltage or any voltage generated which appears at an output terminal, and not voltages generated within and confined internally to the equipment. However, even in the case of equipment which falls outside this scope, there are good reasons to take a similar approach to that required under the Directive when designing and manufacturing electrical apparatus.
A small number of items are excluded from the scope of the directive. In the main these are items which are covered under other more specific directives or which are subject to international legislation outside of the jurisdiction of the EU.
As with the other New Approach directives, the Low Voltage Directive has both
Administrative and Protection requirements. The protection requirements have
been in place since the early seventies, and have been embodied in the
legislation of all EU member states since that time. In the the UK the
implementing legislation is the Low Voltage Electrical Equipment (Safety)
Regulations.
Any competent manufacturer of electrical equipment can meet
these requirements and often already does so without knowing it explicitly.
While requirements are given in annex 1 of
the Directive, these do not specify much that cannot be simply summarised as
'the equipment must be safe' and the specifics of what is safe or not are left
to various standards.
These can be used by manufacturers, purchasers, trading standards officers and
even courts as a bench mark to consider what, in fact, constitutes 'safe'.
The administration requirements are that the product be marked with the
CE
logo, that the manufacturer (or their authorised
representative) complete a specified form of Declaration
of Conformity listing the Directives to which they claim compliance and the
documents (standards) used to justify that claim and that the manufacturer
compile (or be able to compile) a Technical File
containing design details of the product.
Independent product assessment
There is no requirement under the Directive for manufacturers to have their products examined and certified by a third party before they can be CE marked. Manufacturers who feel unsure about the requirements of the standards can involve a consultant or Notified Body if they wish, but this is not mandatory.
There is no exact list of the requirements of the Technical File. Obvious
candidates for inclusion are a circuit/wiring diagram and PCB layout, details of
any calculations made in the design of the appliance, copies of any relevant
test certificates and component data sheets, operating instructions, circuit
descriptions, etc. etc.
The LVD's Technical File is not the same as the
Technical Construction File (TCF) which offers one of the routes to complying
with the EMC
Directive. The purpose of the TCF is to allow a competent body to assess the
reasons that the manufacturer has used to justify their claim of compliance with
the EMC Directive and the only information which is needed is therefore that
which is necessary for an EMC assessment. A product which uses a different route
to compliance with the EMC directive does not require a TCF, but if the product
falls within the requirements of the LVD, it still needs a Technical File.
The LVD's Technical File is more comprehensive and must demonstrate that
the product has been specified correctly and designed according to that
specification.
It is important to understand that the Technical File is
not for general publication - the only people with a right to demand to see it
are the enforcement authorities (the Trading Standards Services in the
UK) so compiling this information is not tantamount to producing a blueprint for
competitors.
Clearly, in the interests of minimising the administration
concerned, it is in manufacturers best interests to make as much information
common between the two files as possible, but it should be remembered that the
LVD Technical File does not require independent assessment whereas the TCF does.
Manufacturers with particular proprietary information which they wish to keep
secret should try to avoid being forced to include this information in a TCF
unless absolutely necessary since clearly they will have less control over where
such a file is circulated.
Useful links
The European Commission have a special section on electrical equipment with a great deal of useful information on their EUROPA server. This includes the full text of the directive, lists of the current harmonised standards as well as guidance and interpretative documents and a list of the national implementing measures in each of the member states of the EU.
For details of draft standards, the New Approach web site is a good EU-funded resource.
The UK government's Department of Trade and Industry (DTI) publish a useful guide on the Directive and this is available for download.
Links to some bodies notified under the directive can be found on our Notified Bodies page.
The best starting point to look for other LVD links is The Safety Link.
As with all CE marking directives, the actual requirements for any piece of equipment under the directive and harmonised standards are complex and dependent on not only the design but also the type of user, the intended use and sometimes even what is claimed in the instructions or sales literature.
For further advice specific to your products, please contact us at
Conformance and we will be pleased to discuss your needs. If you'd like us
to prepare a no-obligation quote for assisting you with CE marking your
products, please take a look at our page which gives details of the information required in order
to be able to give you an accurate idea of the costs and procedures
involved.