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Legal Services for EU Product Conformity Assessment

Directive 2014/35/EU — Low Voltage Directive (LVD)

4 minutes

Directive 2014/35/EU — Low Voltage Directive (LVD)
Immeuble de bureaux

Structured Assessment Logic (SAL) – Your Roadmap for Compliance

SAL Type I – Safety Architecture Framework – NLF-based Comprehensive Safety Framework

Mapping of LVD 2014/35/EU


The SAL comprises the following steps:

  1. Product qualification – Is the product actually within the scope of the LVD?

  2. Selection of the conformity assessment procedure – Module A (self-assessment)

    Under the LVD, manufacturers use a single procedure, Module A, to ensure that their electrical equipment meets the essential safety requirements. This involves carrying out internal checks and maintaining the technical documentation necessary to demonstrate compliance.

  3. Risk assessment – Identification of relevant safety objectives listed in Annex I – Which safety objectives apply to the equipment?

The risk assessment is required not only to evaluate and mitigate hazards, but also to identify which of the Annex I safety objectives are relevant to the specific equipment, based on its design, intended use, and reasonably foreseeable conditions of use.

  1. Assessment of harmonised standards and, where necessary, other means of fulfilment where such standards are not applied or do not exist – Which standards cover the requirements, and where are there gaps?

  2. Technical documentation – Which records demonstrate compliance?

  3. Information and marking obligations

  4. Series Production – How is ongoing conformity ensured?

    Conformity is not limited to design and initial assessment; it must also be maintained throughout ongoing production. In practice, this means identifying and controlling those product and process characteristics whose deviation could compromise compliance with the safety objectives and, therefore, with the legal requirements.

  5. EU Declaration of Conformity & CE marking – Official confirmation of compliance, ready for the EU market.

Note: SAL is not an end in itself. It provides a repeatable methodology that translates regulatory principles into a clear, structured assessment logic.

This diagram illustrates the SAL workflow visually:

Product definition

Safety objectives listed in Annex I

Harmonised standards / other means of fulfilment

Conformity assessment procedure

Technical documentation

Information and marking obligations

Series Production

CE marking & Declaration of Conformity

Interfaces to Related Legislation


When applying LVD 2014/35/EU, there are often intersections with other regulatory frameworks that must be considered simultaneously:

  • Radio equipment legislation

  • Electromagnetic compatibility (EMC) legislation

  • Sector-specific regulations for connected products

A coordinated assessment is therefore necessary to avoid regulatory gaps or duplicated evaluations. In practice, this means SAL provides the roadmap, but it must always be applied in the context of related legislation.

Overview: Directive 2014/35/EU


  • Number: 2014/35/EU

  • Title: Directive relating to the making available on the market of electrical equipment designed for use within certain voltage limits

  • Publication: OJ L 96, 29.3.2014, p. 357

  • Purpose: Establishes a framework for placing electrical equipment on the market

  • Public interest: Product safety

  • Guidance: Guidelines on LVD 2014/35/EU: LVD 2014/35/EU - Guidelines


Scope


The Directive applies to electrical equipment (including some components intended for incorporation into other equipment) designed for the use with a voltage rating:

• between 50 and 1000 V for alternating current;

• between 75 and 1500 V for direct current.

In particular, products such as electrical appliances, lighting equipment, electric wiring, appliance couplers and cord sets, or electrical installation equipment, are covered by the Directive.

Equipment outside the scope of the Directive is listed in Annex II to the Directive.

For “combined products,” see the Supplementary Guidance on the LVD/EMCD/RED.


Conformity Assessment Procedures


Module A (self-assessment).

Manufacturer obligations:

  • Identification of applicable requirements

  • Demonstration of compliance

  • Documentation of applied standards

  • Preparation of the EU Declaration of Conformity

  • Affixing the CE marking

  • Retention of documentation for 10 years

 

Safety objectives under Annex I


The essential safety objectives in Annex I define how electrical equipment must be designed and constructed to ensure safe use and protect users, domestic animals, and property. Key points include:

  • Protection against electrical hazards – prevent electric shocks and related risks

  • Mechanical safety – prevent injuries from moving parts or structural failures

  • Thermal protection – prevent burns, overheating, or fire

  • Radiation, noise, and vibration – minimize harmful emissions and ensure safe operation

  • Safe installation and use – allow correct assembly, connection, and foreseeable use without danger


Note: For practical guidance on interpreting these safety objectives and performing a risk-based assessment, see CENELEC Guide 32, Annex A (link to guide PDF). This guide complements Annex I by providing detailed hazard categories and risk mitigation principles.

Harmonised Standards


 

Information and Marking Obligations


  • Identification and manufacturer marking

  • User manual and safety information

Series Production

The requirement for ongoing conformity is implemented in practice by ensuring that manufacturers identify and keep under control those product and process characteristics whose deviation could jeopardize compliance with the legal requirements.

This requires a systematic management of safety- and compliance-critical characteristics, defining how these characteristics are identified, monitored, controlled, and protected against unintended change.

 

CE Marking


  • Mandatory before placing the product on the EU market

  • Must be visible, legible, and permanent

Conclusion


With SAL, the mapping as a roadmap, and consideration of interfaces to related legislation, it becomes clear how LVD 2014/35/EU is systematically applied. The final workflow logically follows from scope through requirements, standards, and assessment procedures to CE marking – providing a clear orientation for manufacturers, assessors, and all stakeholders seeking regulatory clarity.

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© 2026 by Rechtsanwalt Dr. Matthias K Bauer

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