EU Low Voltage Directive 2014/35/EU: What the Text Says About Scope, Importers and the Declaration of Conformity

Powered products rated within defined voltage bands fall under a directive whose full title never uses the phrase “low voltage”. Directive 2014/35/EU is about “electrical equipment designed for use within certain voltage limits”, and the short name comes from the voltage bands in its first article. For a project buyer who orders such equipment from China for an EU job, the text answers practical questions: which voltage ratings are in scope, who must hold which document, what a CE marking on a luminaire is supposed to rest on, and what the importer in the Union has to check before the goods are placed on the market.

This article reads the Directive as published in the Official Journal of the European Union on 29 March 2014 (EUR-Lex), which we downloaded from the Publications Office on 24 October 2026, and quotes or closely paraphrases the articles and annexes. We did not check whether any later act has amended it, and we did not read the Commission’s guidance, the list of harmonised standards or any Member State’s transposing law. It is a reading of the text for procurement planning, not legal advice, and it does not decide whether a given product is in scope.

The scope: two voltage bands and a list of exclusions

Article 1 sets the purpose, which is to ensure that electrical equipment on the market fulfils the requirements for a high level of protection of health and safety of persons and of domestic animals and property, while guaranteeing the functioning of the internal market. It then defines the scope in one sentence: the Directive applies to “electrical equipment designed for use with a voltage rating of between 50 and 1 000 V for alternating current and between 75 and 1 500 V for direct current, other than the equipment and phenomena listed in Annex II.”

Three readings follow from the wording. The bands are voltage ratings, 50 to 1,000 V AC and 75 to 1,500 V DC, so a 230 V or 400 V AC product sits inside the AC band. The test is the voltage rating the equipment is designed for. And the text we read does not use the phrase “high voltage” at all: anything outside the bands is simply outside Article 1. Which rating applies to a product made of several parts, such as a mains-powered driver feeding a low-voltage load, is a question for the manufacturer’s conformity file rather than something to assume.

Annex II lists what is outside the Directive:

• electrical equipment for use in an explosive atmosphere;
• electrical equipment for radiology and medical purposes;
• electrical parts for goods and passenger lifts;
• electricity meters;
• plugs and socket outlets for domestic use;
• electric fence controllers;
• radio-electrical interference;
• specialised electrical equipment for use on ships, aircraft or railways which complies with the safety provisions drawn up by international bodies in which the Member States participate;
• custom-built evaluation kits destined for professionals to be used solely at research and development facilities.

The list names plugs and socket outlets for domestic use but does not name switches, luminaires or drivers. Recital 4 adds that the Directive covers equipment “new to the Union market when it is placed on the market”, which it explains as either new equipment made by a manufacturer established in the Union or equipment, “whether new or second-hand, imported from a third country”. Recital 5 says it applies to all forms of supply, including distance selling. Article 2 defines placing on the market as the first making available of equipment on the Union market, and the duties in Articles 6 and 8 are framed around that moment. Who counts as the importer for a given project purchase is for the buyer and its adviser to settle before the order.

Who is who: the four economic operators

Article 2 defines the roles. The manufacturer is whoever manufactures electrical equipment or has it designed or manufactured, and markets it under their own name or trade mark. The importer is a person “established within the Union who places electrical equipment from a third country on the Union market”. The distributor is anyone in the supply chain other than the manufacturer or importer who makes the equipment available. The authorised representative is a person established in the Union with a written mandate from a manufacturer to act on their behalf for specified tasks.

Article 10 closes a gap that matters for project buyers who brand goods: an importer or distributor “shall be considered a manufacturer” and takes on the manufacturer’s Article 6 obligations where they place equipment on the market under their own name or trade mark, or modify equipment already on the market in a way that may affect compliance. Recital 13 gives the reason. A contractor or developer that has a luminaire made to its own specification and sells or supplies it under its own name should read Article 6 as applying to itself.

The table sets out the main duties side by side, as the articles state them.

Article 11 adds a traceability duty that runs through the whole chain: on request, each operator must identify to the market surveillance authorities who supplied them with equipment and to whom they supplied it, and be able to do so for 10 years after supply. Article 7 allows a manufacturer to appoint an authorised representative by written mandate, but states that the Article 6(1) obligation on design and manufacture and the obligation to draw up the technical documentation “shall not form part of the authorised representative’s mandate”.

How conformity is shown: safety objectives, standards and the file

The Directive does not contain technical specifications. Recital 16 says it “should be limited to the expression of the safety objectives”, and Annex I lists them as principal elements: the essential characteristics must be marked on the equipment or an accompanying document; the equipment and its parts must be made so that they can be safely assembled and connected; persons, domestic animals and property must be protected against hazards from the equipment, including direct or indirect contact, dangerous temperatures, arcs or radiation, and non-electrical dangers, and the insulation must be suitable for foreseeable conditions; and the equipment must withstand expected mechanical and environmental influences and foreseeable overload without endangering persons, domestic animals or property.

The detail comes from standards. Under Article 12, equipment in conformity with harmonised standards whose references have been published in the Official Journal “shall be presumed to be in conformity with the safety objectives” those standards cover. Where no harmonised standards exist, Article 13 allows the safety provisions of International Electrotechnical Commission standards to be regarded as complying once the notification and publication procedure in that article has been applied, and Article 14 provides a further fallback for national standards of the Member State of manufacture that ensure an equivalent level of safety. The reference list itself is outside the text and we did not read it.

The conformity assessment procedure is the manufacturer’s own. Recital 9 says that the manufacturer, “having detailed knowledge of the design and production process, is best placed to carry out the conformity assessment procedure”, that it “should therefore remain solely the obligation of the manufacturer”, and that “there is no conformity assessment procedure in this Directive which requires the intervention of a notified body.” Annex III sets out that procedure, which it calls Module A, internal production control, and under which the manufacturer “ensures and declares on his sole responsibility” that the equipment satisfies the Directive.

The evidence is therefore a file the manufacturer holds. Annex III requires technical documentation that makes it possible to assess conformity and includes an adequate analysis and assessment of the risks, containing at least, where applicable:

• a general description of the electrical equipment;
• conceptual design and manufacturing drawings and schemes of components, sub-assemblies and circuits;
• descriptions and explanations needed to understand those drawings and the operation of the equipment;
• a list of the harmonised, international or national standards applied in full or in part, and, where they were not applied, descriptions of the solutions adopted to meet the safety objectives; where standards were applied in part, the parts applied;
• results of design calculations and examinations carried out; and
• test reports.

Annex III also requires the manufacturer to take all measures necessary so that the manufacturing process and its monitoring ensure that the equipment made conforms to that documentation. Article 6(4) repeats the point for series production and adds that changes in product design or characteristics, and changes in the standards by reference to which conformity is declared, must be adequately taken into account. A declaration made for a sample therefore has to keep matching what leaves the line.

The EU declaration of conformity and the CE marking

Under Article 15, the EU declaration of conformity states that the fulfilment of the safety objectives “has been demonstrated”. It follows the model in Annex IV, contains the elements of Module A, and “shall be continuously updated”. It must be translated into the language or languages required by the Member State in which the equipment is placed or made available. Where equipment is subject to more than one Union act requiring such a declaration, a single declaration is drawn up that identifies all the acts concerned with their publication references. By drawing it up, the manufacturer “assume[s] responsibility for the compliance of the electrical equipment”.

The Annex IV model has seven numbered points: the product model or product (type, batch or serial number); the name and address of the manufacturer or authorised representative; a statement that the declaration is issued under the sole responsibility of the manufacturer; the object of the declaration, identified so that it can be traced, with a colour image if needed; a statement that the object conforms to the relevant Union harmonisation legislation; references to the harmonised standards or other technical specifications used; and additional information, followed by place, date, name, function and signature. Assigning a number to the declaration is optional.

On the marking, Article 17 requires the CE marking to be affixed “visibly, legibly and indelibly” to the equipment or its data plate; where that is not possible or not warranted by the nature of the equipment, it goes on the packaging and the accompanying documents. It must be affixed before the equipment is placed on the market. Article 16 refers the general principles of the marking to Article 30 of Regulation (EC) No 765/2008, which we did not read. Put together, the order in the text is: safety objectives, then the technical file and conformity assessment, then the declaration, then the marking. A CE marking with no declaration and no file behind it has skipped the steps that Article 6(2) places before it.

Dates and who the Directive addresses

Article 26 required Member States to adopt and publish the laws needed to comply with its operative articles and Annexes II to IV by 19 April 2016 and to apply them from 20 April 2016. Article 27 repealed Directive 2006/95/EC with effect from 20 April 2016, and Article 28 says certain provisions, including Article 1 and Annex I, apply from that date. Article 29 states that the Directive “is addressed to the Member States”. In practice that means the obligations on manufacturers and importers described above reach them through the national laws that transpose the Directive, and an importer should check the transposing law of the Member State where the goods are placed on the market. We did not read any of those laws.

Article 18 applies Articles 16 to 29 of Regulation (EC) No 765/2008 on market surveillance and controls of products entering the Union market to electrical equipment, and Article 19 describes how market surveillance authorities deal with equipment that presents a risk, including requiring the economic operator to take corrective action, withdraw or recall. We have not set out those procedures or any penalties, which are matters for national law.

What to request from a bidder before ordering

For electrical equipment going to an EU project, the text suggests these documents. They are evidence requests, not a legal checklist.

• The EU declaration of conformity in the Annex IV structure, naming the manufacturer and its address, identifying the exact product model, and listing the standards or other technical specifications relied on.
• Confirmation that the declaration also names the other Union acts that apply to the product, as Article 15(3) requires for a single declaration.
• Confirmation that a technical file exists with the Annex III contents, including the list of standards applied and the test reports, and that the manufacturer will hold it for 10 years after the equipment is placed on the market.
• The test reports that correspond to the model ordered, not to a different model in the same range.
• Marking on the product: the manufacturer’s name and a single postal address, a type, batch or serial number, and the CE marking on the product or data plate, or on the packaging and documents where that is not possible.
• Instructions and safety information in the language required where the product is made available.
• A clear answer on who is the manufacturer, who is the importer in the Union and whether an authorised representative has been appointed, because Articles 8 and 10 attach duties to those roles.

Related guides cover the other pieces of an electrical package. Our note on UKCA vs CE marking for China-made products covers the UK position; voltage and electrical standards for lighting and appliances sets out supply voltages by region; UL listing for lighting from China covers the US; and LM-80, TM-21 and L70 explains the lifetime figure on an LED luminaire quotation, which is a separate question from safety conformity.

Frequently asked questions about the EU Low Voltage Directive

What voltages does Directive 2014/35/EU cover?

Article 1 applies it to electrical equipment designed for use with a voltage rating of between 50 and 1,000 V for alternating current and between 75 and 1,500 V for direct current, other than the equipment listed in Annex II. A 400 V AC product is inside the AC band.

Is an EU directive mandatory?

Article 29 states that this Directive is addressed to the Member States, and Article 26 required them to adopt and publish the laws needed to comply and to apply them from 20 April 2016. The obligations on manufacturers and importers therefore reach them through the transposing national law of the Member State concerned.

Does a CE marking on electrical equipment mean a notified body certified it?

Not under this Directive. Recital 9 states that no conformity assessment procedure in it requires the intervention of a notified body. Under Annex III the manufacturer carries out the assessment and declares conformity on its sole responsibility, and the technical documentation must include test reports, so the evidence to ask for is the declaration and the file behind it.

What must an importer check before placing electrical equipment on the market?

Article 8 says the importer must ensure that the manufacturer has carried out the conformity assessment procedure, drawn up the technical documentation, affixed the CE marking, supplied the required documents and met the identification and address requirements. The importer must also add its own name and postal address, ensure instructions and safety information accompany the equipment, and keep a copy of the EU declaration of conformity for 10 years.

When does an importer or distributor count as the manufacturer?

Under Article 10, when it places electrical equipment on the market under its own name or trade mark, or modifies equipment already placed on the market in such a way that compliance with the Directive may be affected. It then carries the manufacturer’s Article 6 obligations.

How does FBM Sourcing support this kind of project?

We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and the client’s project team is welcome to attend.

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