COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE EVALUATION of the Low Voltage Directive 2014/35/EU
Date: 2021-07-14
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EC conformity marking, electrical equipment, electronic commerce, free movement of goods, harmonisation of standards, market supervision, product safety, safety standard, single market, technical standard

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   EUROPEAN COMMISSION  Brussels, 14.7.2021  SWD(2021) 203 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE EVALUATION  of the Low Voltage Directive 2014/35/EU {SWD(2021) 202 final}  
 
 
EXECUTIVE SUMMARY 

The  Low  Voltage  Directive  2014/35/EU  (LVD)  evaluation  is  carried  out  as  part  of  the 
Commission’s Regulatory Fitness and Performance (REFIT) programme. The evaluation covers 
all  relevant  electrical  equipment  in  the  Directive’s  scope  and  33  countries  (EU28,  EFTA,  and 
Turkey).  It  focuses  on  the  period  from  2014  after  the  Directive’s  alignment  to  the  New 
Legislative framework. 

The  purpose  is  to  review  the  performance  of  the  Directive  according  to  the  five  criteria: 
relevance, effectiveness, efficiency coherence, and EU added value.  

The  LVD  has  two  main  objectives:  it  provides  that  electrical  equipment  is  safe  for  persons, 
domestic animals and property and it guarantees free movement of products within the internal 
market. 

Two  significant  developments  affected  the  LVD  during  the  last  decade.  First,  electrical 
equipment  embeds  more  and  more  computing  devices  allowing  them  to  send  and  receive  data 
wirelessly  (Internet  of  Things)  and  hence  are  now  covered  by  the  Radio  Equipment  Directive 
2014/53/EU and  no  more by  the  LVD.  Second,  the continuous  growth  of  e-commerce  changes 
the  way  consumers  shop  on  a  large  scale1,  affecting  the  ability  to  perform  effective  market 
surveillance. The development of e-commerce leaves room for uncompliant products in the EU 
market, affecting the level playing field.  

Stakeholders generally agree that the objectives of the LVD are still relevant today. This is true 
for  both  health  and  safety  of  persons,  domestic  animals  and  property,  and  free  circulation  of 
products within the internal market.  

The increased number of products wirelessly connected to the internet has reduced the scope of 
the  LVD,  given  that  wireless  connected  LVD  products  fall  within  the  scope  of  the  Radio 
Equipment Directive (RED). Nevertheless, the safety provisions of the LVD continue to apply.  

Also,  the  Directive  still  responds  to  the  current  needs  of  free  circulation  because  it  prevents 
diverging  regulations  between  the  EU  Member  States,  and  it  favours  the  intra  EU  trade  with 
benefits for both economic operators and consumers. 

The  LVD  is  generally  seen  as  contributing  to  an  effectively  operating  internal  market  for 
electrical  equipment  in  its  scope.  It  facilitates  intra-EU  trade  by  establishing  a  set  of  rules  and 
procedures that are integrated into the harmonised standards. All interested parties confirmed that 
standards  are  effective  means  to  comply  with  the  Directive  while  keeping  pace  with 
technological  innovations.  No  major  cases  of  discrepancies  have  been  detected  across  the  EU 
Member States in implementing the LVD.  

Overall,  stakeholders  are  relatively  positive  on  the  Directive’s  effectiveness  for  health  and 
safety.  Though  highlighted  by  some  stakeholders,  the  absence  of  third  party  involvement  for 
assessing the conformity of low voltage products is not seen as having a negative impact on the 
safety  by  the  majority  of  them.  Some  stakeholders,  including  consumer  organisations,  suggest 
imposing a mandatory third party certification for a category list of “risky products”. However, 
such list is not defined by the LVD.  

Concerning  efficiency,  all  stakeholders  bearing  the  cost  stemming  from  the  LVD  consider  the 
benefits  outweighing  its  costs.  Economic  operators  acknowledge  the  importance  of  the  use  of 

1 With 40% of consumers preferring to buy consumer electronics online PWC, Global Consumer Insight 
Survey (2018). 

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standards.  However  some,  in  particular  SMEs,  feel  that  they  are  too  costly.  Procedural 
compliance  costs,  administrative  costs,  and  specific  resource  costs  for  economic  operators  are 
generally  considered  less  problematic.  Economic  operators  suggest  reducing  costs  related  to 
marking and documentation by using internet-related solutions in combination with information 
on the product/in manuals.  

The coherence with the Radio Equipment Directive and the Machinery Directive raised issues in 
determining  to  what  extent  a  product  should  fall  under  each  Directive.  Nevertheless,  most 
stakeholders  considered  that  these  issues  do  not  stem  from  the  LVD.  In  this  regard,  the  recent 
revision of the Machinery Directive has brought legal clarity on the issue. 

Overall,  the  LVD  brings  EU  added  value,  providing  a  common  set  of  rules  and  standards, 
facilitating the free circulation of compliant products within the internal market and guarantee a 
high level of safety of products across the EU.  

The overall conclusion is that the Directive is relevant, effective, efficient, coherent, and has EU 
added value. However, specific issues have been identified.  

  Some  stakeholders  suggest  imposing  a  mandatory  involvement  of  third  parties  for 
products  that  could  be  classified  as  high-risk  products.  However,  the  majority  of 
stakeholders  views  are  positive  towards  the  current  conformity  procedure  arguing  that 
such change  would  not address  the safety  of  products.  Additionally,  the  LVD  does  not 
make the distinction between classes of risks.  

  Economic  operators  would  welcome  the  introduction  of  internet  related  solutions  for 
marking and documentation. However, consumers feel that it will decrease their ability to 
find and understand the information. 

  Coherence issues  with  the MD  and  the  RED  remain and  stakeholders  would like  more 
clarity. In this respect, the proposal for the revised MD aims at bringing greater clarity to 
the  interplay  between  the  LVD  and  the  MD.  The  evaluation  does  not  indicate  that  a 
merger between the LVD and the RED would be beneficial.  

  Some  stakeholders  suggest  the  possible  inclusion  of  products  with  a  very  low  voltage 
limit  (currently  excluded  by  the  LVD).  However,  views  are  diverging  with  no  clear 
indication if such change would be beneficial.  

Other issues were identified but fall outside the remit of the LVD. 

  Member  States  have  different  abilities  to  identify  uncompliant  products  during  the 
conformity  assessment  procedure,  and  this  might  create  an  uneven  playing  field. 
Furthermore, due to the introduction of Wi-Fi connection in equipment, competency gaps 
for the testing and market surveillance authorities can appear. Overall,  the effectiveness 
of market surveillance activities is currently seen as uneven throughout the EU.  

  The increased  phenomenon  of  e-commerce  makes  it  challenging  to  sample  products or 
conduct risk assessments. Also, this leaves room for uncompliant products to be sold by 
extra-EU competitors in the internal market.  

On the latter two, some steps are taken for increased clarity of e-commerce rules2 but challenges 
remain in particular related to market surveillance. The Goods Package 2017 as well as the new 
market surveillance Regulation (EU) 2019/1020 should address both concerns. 

2 A Commission Notice on the market surveillance of products sold online (2017/C 250/01) was published: 

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https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52017XC0801%2801%29 

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