CE-LVD
The new low voltage instruction 2014/35/EU will come into effect on April 20, 2016. As the instructions are updated, the EC will implement the Low Voltage Directive Regulations in accordance with the new legislative framework.
The New Legislative Framework (NLF) was published in 2008. NLF aims to help the EU product market operate better, and to strengthen and update the conditions of use for the sale of industrial products in the EU market in a wide range of areas. As a component of the Cooperative Coordination Pack, the new low voltage instruction is one of eight NLF-compliant instructions.
The change of low voltage instruction (LVD) is reflected in NLF. The new instruction does not introduce technical change.
The new version of the Low Voltage Directive (2014/35/EU) specifies the obligations of distributors in more detail than the current Directive (2006/95/EC). "Distributor" means manufacturer, authorized representative, importer and distributor. Detailed obligations are required to ensure that the product meets the requirements throughout the supply chain up to the end user. Distributors who put products into the market bear the main responsibility, and distributors should also bear part of the responsibility.
The traceability of distributors in the whole supply chain should be very clear. For example, the manufacturer's name, registered commodity name, or registered trademark mark mark and communication address should be marked on the product. Current LVD only requires clearly labeling the trademark name or registered trademark mark mark on the product. If the product is imported into Europe, it is necessary to label the name and communication address of the manufacturer and importer on the product.
Product information corresponding to conformity declaration and technical documents (such as model number, serial number batch) should be clearly marked on the product. The manufacturer needs to prepare technical documentation. Only according to the technical documentation can the manufacturer evaluate whether the electrical equipment meets the relevant requirements. At the same time, the technical documents also include risk assessment and necessary measures taken to address the risks. The manufacturer is responsible for risk assessment and necessary measures for specific risks. The current LVD does not specify that the product needs risk analysis and assessment.
In Annex IV, the new version of LVD introduces a mandatory compliance declaration template. Manufacturers and authorized representatives or importers must provide compliance statements when required by the relevant authorities.
Another major change is the clarification of the definition of "manufacturer". "Manufacturer" means a natural or legal person who manufactures or owns electrical equipment designed or manufactured by him and sells the product on the market with his name or trademark.
If the importer or distributor uses his own name or trademark to sell electrical equipment in the market, according to LVD, it will be considered a manufacturer and fulfill the manufacturer's obligations. If the importer or distributor modifies the electrical equipment already sold on the market and affects the LVD conformity of the product, it will also perform the responsibilities and obligations of the manufacturer.
The new LVD (2014/35/EU) will come into effect on April 20, 2016. Prior to this, the compliance statement should be consistent with the current LVD (2006/95/EC), without reference to the new version of LVD (2014/35/EU). Because the security objective remains unchanged, any reference document for the current LVD (2006/95/EC) can be used as a compliance assessment from a security perspective. Therefore, when the product is changed from conforming to the current LVD (2006/95/EC) to conforming to the new LVD (2014/35/EU), the distributor should pay attention to its obligations and responsibilities.
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