• Low Voltage Directive (LVD): Compliance When Importing Electronics to Europe

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    Low Voltage Directive

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    What is the aim of the Low Voltage Directive?

    The Low Voltage Directive (LVD) is one of the first European CE directives. Its main goal is to ensure that all the electrical devices by an EU member (France, for instance) approved by a country that belongs to the European Union are also conforming to the laws of all the other members of the EU, especially for what concerns safety regulations.

    As for many other CE directives, the LVD doesn’t define any specific technical standard itself. Instead, it refers to a list of specific IEC/ISO EN norms that both European manufacturers and importers must respect.

    What categories of products fall within the scope of the Low Voltage Directive?

    The LVD covers electrical and electronics devices with an input or output voltage between 50 and 1000 Volt for alternating current (AC), or a voltage ranging between 75 to 1500 Volts, for Direct Current (DC).

    Notice that the LVD directive doesn’t cover the voltage that may be developed inside the device, unless the user can accede to the internal components without using an instrument such as a screwdriver or a hammer.

    So, if the equipment has an input and output voltage lower than 50 Voltage and the user can’t accede to its internal components without disassembling it with an instrument, then you can safely assume that the LVD is not applicable. This holds true, even if the internal components of the electrical equipment may develop a voltage above 50 Volts.

    Also, the LVD only applies to fully assembled products; components such as capacitors or microchips are excluded no matter their input or output tension.

    However, there are also exceptions, when LVD is not applicable, despite the items falling within the general scope of definition.

    What products are excluded from the Low Voltage Directive?

    Here’s a non-exhaustive list of products that are excluded from the LVD:

    • The products that already fall within the scope of other directives that already imply LVD’s technical requirements such as the product that fall within the scope of R&TTE (Radio and Telecommunications Terminal Directive), ATEX (Safety on Potentially Explosive Atmospheres) and others
    • Plugs for domestic use
    • Electrical material specifically designed for ships, airplanes or trains

    Is LVD compliance enough to guarantee CE compliance?

    Even if there are exceptions, most of the devices that fall within the scope of LVD also fall within the scope of other directives. Take, for instance, an electrical motor: it’s possible that it will also fall within the scope of RoHS, EMC and/or Eco design directives.

    There are products that must comply with up to five directives, in order to be legally imported to the EU. If you aren’t sure of what directives apply to your product, we can confirm applicable EU directives and standards for you. Click here to learn more about our Starter Package.

    What labeling requirements and documents does the Low Voltage Directive require?

    The products that fall within the scope of the LVD must be CE marked. The importer must also possess the Declaration of Conformity and the technical documentation.

    Does most of Chinese suppliers comply with the Low Voltage Directive?

    No. Not more than 5-10% of Chinese suppliers have the technical capability (and the interest) to comply with the LVD, and the others directives regulating electrical equipment and electronic products.

    It makes perfect sense. The main market of most of Chinese suppliers isn’t the European Union. Instead, many of them focus on the domestic Chinese market or on developing markets such as Russia, South East Asia or Africa.

    The quality and security standards in these markets are less strict than those in the EU and some developing countries lack electrical safety regulations all together. This means that manufacturing a product that complies with European regulations is more expensive (because the manufacturer must use high quality material and components and, often, specific machinery) and more difficult (because the IEC/ISO EN norms may require specific procedures or environments).

    The result is that most of Chinese manufacturers don’t comply with EU regulations, either because they have strict price constraints in order to stay competitive in the developing markets or because they simply lack the technical skill and knowledge on manufacturing items according to, rather strict, LVD.

    What happens if I to import non-compliant products?

    First of all, you risk major fines, sometimes counted in the millions of Euros and that your goods will be refused entry by the customs authority in your country. At the time of entry, you’ll have already paid your supplier (usually the last payment is done when the goods are loaded onto the container at the Chinese departure port). As a result, non-compliance that is discovered after the cargo is shipped from China, is most likely going to result in a total loss, as you cannot expect any compensation from your Chinese manufacturer.

    But that is not all that might ruin your day. Ensuring LVD compliance is especially important because it’s a directive that focus on the electrical safety and the consequences may be terrible: if, for instance, you import non LVD compliant power supplies for smartphones and your client answers to a call while he’s charging his phone, he risks death from electrocution.

    I know this may seem a bit dramatic, but it already happened several times. Even if nobody dies while answering his phone, there could be a fire due to an electrical short-circuit.

    Guess who goes to jail in this case? Even if all European directives state that the manufacturer is the only responsible for guaranteeing product compliance, you’re the one that is going to jail, not the Chinese supplier.

    The misunderstanding comes from the fact that directives refer to European manufacturers. However, if the products are manufactured outside the EU, the importer is, from a legal point of view, considered being the manufacturer.

    Thus, instead of blaming you Chinese supplier, make sure to choose one that is able to manufacture LVD compliant items. Remember, you only have one chance, and you must get it right from the start as you can’t make non-compliant items become compliant.

    How can I minimize the risk of importing non compliant products?

    Choose a supplier that can show previous compliance

    Let’s assume that Supplier A exports in Europe on a regular basis and have several CE test reports signed by a recognized Lab such as SGS or TUV. Then there is Supplier B, which has no test reports. However, he promises to get a CE certificate as soon as you wire him the money for the order and, by the way, he’s the cheapest LED lights supplier on the market.

    Now, this is a very common situation because, as I already said, manufacturing CE compliant goods is more expensive. Thus, LVD compliant suppliers are rarely the cheapest on the market. The problem is that, since they don’t know the risks they are being exposed, many importers choose to place their order with supplier B, even if they have no idea whether he will be able to manufacturer compliant goods or not.

    Why? Because few Chinese suppliers can do it and, if a supplier can’t show any previous compliance, it’s quite likely that it will fail to manufacture a product that can pass the compliance tests.

    So you may get a cheaper product, but it will probably be illegal in the EU.

    The first step is simple: only choose suppliers that can prove (“prove” means that they have valid test reports) they already manufactured CE compliant products in the past. Since they already did it, there are good chances that they will be able to do it again.

    Send a batch sample for lab testing

    Let’s say that your supplier claims that he’s able to manufacture CE compliant LED lamps and he can back up his claims with several test reports from last year. Does previous compliance guarantees future compliance?

    Not at all.

    For your batch, he may choose to save money and use cheap and substandard components or, simply, his new welder may be defective. There are many things that can go wrong during production, especially when it comes down to complex electric appliances.

    Thus, the only way to make sure that your batch is compliant is to send a batch sample to a lab for a test. There is no other way around.

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