Does my product fall under the Low Voltage Directive?

The voltage range

The directive concerns electrical equipment with a nominal voltage of 50 to 1,000 volts AC. For DC, this is 75 to 1,500 volts. These limits are strict. They concern the voltage at which the equipment operates, not the voltage from the wall socket.

This distinction determines who must demonstrate what more often than expected. A device that operates at 12 volts via an external adapter falls outside the scope itself. The adapter, which connects to the mains, does fall under it. Your file must therefore clearly state which part falls under which regulation.

The directive does not set requirements for product performance but for safety: protection against electric shock, excessive temperatures, mechanical risks, and risks originating from outside the equipment.

What happens below the limit

Products that operate solely on batteries or via USB are generally below the lower limit. They then do not fall under the Low Voltage Directive. This does not mean no requirements apply: the General Product Safety Regulation remains applicable, and the included adapter does fall under the LVD.

We see this go wrong in both directions. Some files list the LVD for a product running on 5 volts, suggesting that something has been assessed that is not applicable. Other files omit the adapter entirely, even though that is where the risk lies.

Why radio equipment works differently

If your product has a radio function, such as Wi-Fi or Bluetooth, the Radio Equipment Directive applies. That directive then fully covers the safety requirements for that product itself. It refers to the safety objectives of the Low Voltage Directive for this purpose but does not maintain the 50-volt lower limit.

In practical terms, this means you do not list the LVD separately in your Declaration of Conformity. This is one of the most common errors in declarations for wireless products, where the RED, LVD, and EMC Directive are all mentioned, even though the first already covers the other two.

The standards you usually need

Which standard applies depends on the product type. For audio, video, and information technology, this is usually EN 62368-1. Household appliances follow the EN 60335 series, lighting the EN 60598 series, and measurement and laboratory equipment the EN 61010-1 standard. Each series has its own Part 2.

• EN 62368-1 for audio, video, information, and communication technology.
• EN 60335-1 with a Part 2 per appliance type, for household and similar appliances.
• EN 60598-1 with a Part 2 per type of luminaire, for lighting.
• EN 61010-1 for measurement, control, and laboratory equipment.

The series with a Part 2 are important. A report that only refers to the general part misses the requirements specifically applicable to your type of device.

What happens during a test

An assessment under the LVD combines measurements with a construction assessment. It examines insulation distances, earthing continuity, temperature rise under load, dielectric strength, mechanical robustness, and the design of the power supply. Documentation and product marking are also part of this assessment.

The latter two are often underestimated. Missing warnings, incorrect power ratings, or a manual without safety instructions lead to findings, even if the product is electrically sound.

Why products fail

In our practice, four causes recur constantly: insufficient creepage and clearance distances on the PCB; a power supply that becomes too hot at full load; a housing that allows access to live parts under load; and markings or instructions that are missing or incorrect.

• Insulation distances. Often the result of a PCB design optimized for size.
• Temperature. Visible during the continuous load test, not during short-term use.
• Accessibility. Test fingers and test pins reach places that seem closed during normal use.
• Documentation. A missing warning is a finding, even without an electrical problem.

What you need to arrange

First, determine whether your product falls within the voltage range and whether there is a radio function. Then, request the reports for each component, including those for the adapter. Check whether the standard has been applied with the correct Part 2 and whether the type number matches what you are selling.

1. Note the nominal voltage at which the product operates and determine if it falls within the range.
2. Check if there is a radio function. If so, safety is handled via the Radio Equipment Directive.
3. Request the adapter report separately, including the type number.
4. Check if the applied standard includes the correct Part 2 for your type of device.
5. Review the marking and the manual for mandatory warnings and indications.