The Scope of the Low Voltage Directive

The Directive states that it applies to all apparatus operating on any AC supply between 50 and 1000 volts or DC supply between 75 and 1000 volts.

A common question relating to the LVD is whether or not this means only products which are supplied from a source within this range or also to those which are powered from a lower voltage source but generate voltages within this range as part of their operation.

The UK legislation (and indeed, the Directive itself) are unclear on this point, but guidelines on the Directive published by the European Commission in July 1997 state:

"The Directive applies to all electrical equipment designed for use with a voltage rating of between 50 and 1000V for alternating current and between 75 and 1500V for direct current. Voltage ratings refer to the voltage of the electrical input or output, not to voltages which may appear inside the equipment."

Manufacturers, particularly selling within the UK, would do well to treat these words with some caution. The wording of the UK legislation (the Electrical Equipment (Safety) Regulations 1994, SI1994:3260) is as follows:

"4. (1) .....these Regulations apply to any electrical equipment .... designed or adapted for use with voltages (in the case of alternating current) of not less than 50 volts or not more than 1000 volts or (in the case of direct current) of not less than 75 volts nor more than 1500 volts."

Under English law, the law is what is written, not what was meant to be written, and the law seems rather less clear than the EC guidance. The final interpretation of any wording in Regulations and Acts of Parliament is a matter for the courts, and Conformance makes no claim to provide legal advice, but the purpose of this legislation is product safety oriented. While it obviously does matter how these voltages are actually produced, in so far as that will affect how they can be applied to the body, the legislation does not make this distinction since it would have to go into undesirable detail so to do. Clearly it is possible to conceive of a product which can generate a lethal voltage even if it actually derives its original source of power from a non-lethal source such as a battery. Ergo, the legislation covers all equipment containing potentially lethal voltages howsoever they are actually generated.

The second point is that it actually does not matter very much anyway, since any product which falls within the scope of this argument also falls within the scope of the EMC Directive which means it has to be CE marked whether or not it falls within the scope of the LVD. And the other general safety legislation which covers consumer goods, health and safety and the duty of care between manufacturers, customers and between people in general requires that manufacturers of all electrical products have to show due diligence in the design and manufacture of the equipment they sell. It would be very difficult to argue that a manufacturer who had totally ignored the product safety standards and other industry good practice when they designed and built a product was meeting their obligations under these other requirements.

So, to put it simply, you have to do pretty well everything that you would be doing under the LVD anyway, so what difference does it make?

 

Back to the Conformance LVD page