SAFEGUARDS | Electrical & Electronics NO. 114/15
The New Low Voltage Directive 2014/35/EU will become effective on 20th April 2016. With the updated Directive, the European Commission will implement rules from the new legislative framework to the Low Voltage Directive.
The New Legislative Framework (NLF) was published in 2008. The aim of the NLF is to help the internal market for goods to work better and to strengthen and modernise the conditions for placing a wide range of industrial products in the EU market. The Low Voltage Directive was one of the eight directives harmonised with NLF as a part of a so-called ’Alignment Package’.
Changes in the Low Voltage Directive (LVD) are reflected in the NLF. Technical changes weren’t introduced.
New LVD (2014/35/EU) determines the obligations of economic operators in a more detailed way than the current LVD (2006/95/EC). ‘Economic operators’ means the manufacturer, the authorised representative, the importer and the distributor. The aim of these more detailed obligations is that the product must be compliant during the whole supply chain until it gets to the end user. The main responsibility relies on the economic operator placing the product on the market but the distributors have some limited obligations too.
The traceability of the economic operators through the whole supply chain must be unambiguous. For example, the name, registered trade name or registered trade mark and postal address of the manufacturer must be on the product. The current LVD requires that only the brand name or the trade mark should be clearly printed on the product. When the product is imported to Europe, the name and postal address of the importer must be on the product as well, together with the manufacturer’s name and postal address.
The product must be clearly marked with an element (e.g. type, batch of serial number) that denotes a clear link to the relevant declaration of conformity and to the technical documentation. The manufacturer has to compile the technical documentation, which must make it possible to assess the electrical equipment’s conformity to the relevant requirements. It must also include an adequate analysis and assessment of the risk. The manufacturer is responsible for the risk assessment and the implementation of the necessary measures. The current LVD does not mention explicitly the risk analysis and assessment.
In Annex IV, the new LVD introduces a compulsory template of the Declaration of Conformity. The manufacturer, and the authorised representative or the importer, must make the Declaration of Conformity available upon the request of the authorities.
One of the major changes is the clarification of the definition ’manufacturer’.
'Manufacturer’ means any natural or legal person who manufactures electrical equipment or has electrical equipment designed or manufactured, and markets that equipment under his name or trade mark.
If an importer or distributor places electrical equipment on the market under its own name or trade mark, that company are considered a manufacturer for the purposes of LVD and will be subject to the obligations of the manufacturer. The same applies if an importer or distributor modifies electrical equipment already on the market in such a way that compliance with LVD may be affected.
The new LVD (2014/35/EU) will become effective on 20th April 2016. Before that, Declarations of Conformity must be in line with current LVD (2006/95/EC) and not refer to the new LVD (2014/35/EU). The reason is that, since safety objectives remain the same, any reference to the current LVD (2006/95/EC) would encourage a presumption of conformity from the safety point of view. Therefore, economic operators must pay attention to their obligations (and to their product documentation) when transferring their product from current LVD (2006/95/EC) to the new LVD (2014/35/EU).
- Low Voltage Directive 2014/35/EU 
- The ’Blue Guide’ on the implementation of EU product rules, 2014 
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