A guide into stress-free product compliance

Low Voltage Directive (LVD)

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

Objection!

The following standards are no longer harmonised because member states raised formal objections. These standards are therefore no longer sufficient to declare conformity your products.

EN 60335-2-9:2003
Grills and toasters
Germany and Norway raised formal objections on the missing tests and warnings for hot surfaces of these products.

EN 60335-2-14:2006
Blenders
Germany raised a formal objection on the possibility to operate blenders when the cutting blades are accessible to the user.

EN 60335-2-24:2010
Refrigerators
After fatalities and fires the UK raised a formal objection on missing flammability requirements for upright household fridge freezers.

EN 60335-2-60:2003
Whirlpool spas
After two nearly fatal accidents The Netherlands raised a formal objection and requested elimination of the shortcomings in the current standard.


"Manufacturers shall ensure that products remain in conformity with the LVD when changes in the harmonised standards occur".

LVD Article 12 - Presumption of conformity
Electrical equipment which is in conformity with published harmonised standards shall be presumed to be in conformity with the safety objectives of Low Voltage Directive 2014/35/EU.

All products must comply with the principal elements of the safety provisions in Annex I of the Low Voltage Directive 2014/35/EU.

Follow these three steps to prove the conformity of your products when harmonised standards are no longer available:

1. Risk assessment

Start with an adequate analysis and assessment of the risks.
Make an inventory of the risks that may occur during intended and foreseeable use of your product.
Follow incidents with similar products in the market, regularly check recall websites (for instance Europe's RAPEX or CPSC in the USA).
Store the assessment in your technical file.

2. Evidence

Check if the already available test reports cover some of the risks you have identified in the assessment.
Study the formal objections to establish which risks are not covered by a harmonised standard. Decide if the objections are relevant for your products as well. If this is the case then make sure you address these risks adequately by an alternative method or standard. You might even have to change the design of your product to avoid or lower the risk.
The complete texts of the formal objections are available as resources for all users of ProductIP users that create technical files.

3. Technical file

Describe all the solutions that you applied to meet the safety objectives of the Low Voltage Directive in your technical file. This includes specific and detailed information about the (previously) harmonised standards applied in full or in part, other international or national standards and other relevant technical specifications that you have applied.


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