COMMISSION STAFF WORKING DOCUMENT 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

EN 

  EN 

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

1 

INTRODUCTION ................................................................................................................................ 1 

Purpose of the evaluation ............................................................................................................ 1 

Scope of the evaluation ............................................................................................................... 2 

2 

BACKGROUND TO THE INTERVENTION ..................................................................................... 2 

Description of the Low Voltage Directive and its objectives ...................................................... 2 

Previous Low Voltage Directives and changes introduced by the current Directive (LVD) ...... 3 

3 

IMPLEMENTATION / STATE OF PLAY .......................................................................................... 5 

Relevant Bodies ........................................................................................................................... 5 

Guidelines.................................................................................................................................... 6 

European standardisation ............................................................................................................ 6 

4  METHODOLOGY ................................................................................................................................ 6 

Data collection and consultation strategy .................................................................................... 6 

Data analysis methodology ......................................................................................................... 7 

Statistical data on products in the scope of the LVD .................................................................. 7 

Cost-benefit analysis ................................................................................................................... 8 

5 

ANALYSIS OF THE LVD MARKET ................................................................................................. 8 

Economic importance in the EU ................................................................................................. 8 

Intra- and extra-EU trade in low voltage products ...................................................................... 9 

Consumption of low voltage products ....................................................................................... 11 

6 

TRENDS AND DEVELOPMENTS WITHIN THE LOW VOLTAGE MARKET ........................... 11 

Technological innovations: connected systems and the internet of things ................................ 12 

E-Commerce.............................................................................................................................. 12 

7 

ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS .......................................... 12 

Findings in relation to the Effectiveness of the Directive ......................................................... 12 

Findings in relation to the Efficiency of the Directive .............................................................. 23 

Findings in relation to relevance ............................................................................................... 28 

Findings in relation to the Coherence of the Directive (LVD) .................................................. 32 

Findings in relation to the EU Added Value of the LVD .......................................................... 36 

8 

9 

CONCLUSIONS ................................................................................................................................. 38 

ANNEXES .......................................................................................................................................... 40 

ANNEX 1 .................................................................................................................................. 40 

ANNEX 2 .................................................................................................................................. 41 

ANNEX 3 .................................................................................................................................. 58 

ANNEX 4 .................................................................................................................................. 68 

ANNEX 5 .................................................................................................................................. 72 

ANNEX 6 .................................................................................................................................. 76 
1 

 
 
2 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

A&I 

AdCo 

CEN 

Accidents and injuries 

Administrative Cooperation (Group) 

European Committee for Standardization 

CENELEC 

European Committee for Electrotechnical Standardization 

DG GROW 

Directorate-General 
Entrepreneurship and SMEs 

for  Growth 

- 

Internal  Market, 

Industry, 

EEA 

EFTA 

EHSR 

EMCD 

ENs 

EU 

FTE 

hENs 

IEC 

IoT 

LVD 

European Economic Area 

European Free Trade Association 

Essential Health and Safety Requirements 

Electromagnetic Compatibility Directive 2014/30/EU 

European Standards 

European Union 

Full-Time Equivalent 

Harmonised European Standards 

International Electrotechnical Commission 

Internet of Things 

Low Voltage Directive 2014/35/EU 

Evaluation study 

Interim evaluation of the Low Voltage Directive 2014/35/EU 
Final Report by Ecorys, Valdani Vicari & Associati, Deloitte  

MD 

MME 

MSA 

NA 

NACE 

NLF 

OJEU 

Machinery Directive 2006/42/EC 

Manufacture of Machinery and Equipment 

Member States Authorities 

New Approach 

(European)  Classification  of  Economic  Activities 
statistique des Activités économiques dans la Communauté Européenne) 

(Nomenclature 

New Legislative Framework 

Official Journal of the European Union 

Safety Gate/RAPEX 

Rapid Alert System for dangerous non-food products 

3 

 
RED 

REFIT 

RfUs 

Radio Equipment Directive 2014/53/EU 

(Commission's) Regulatory Fitness and Performance 

Recommendation for Use sheets 

4 

 
1 

INTRODUCTION 

Directive  2014/35/EU  on  electrical  equipment  designed  for  use  within  certain  voltage  limits1, 
commonly known as the Low Voltage Directive (LVD), hereafter the Directive, is one of the core 
Union  legislation  regulating  products  of  the  Electrical  and  Electronic  Engineering  Industries, 
alongside  the  Radio  Equipment  Directive  2014/53/EU2  (RED)  and  the  Electromagnetic 
Compatibility Directive 2014/30/EU3 (EMCD). 

. 

PURPOSE OF THE EVALUATION 

The first Low Voltage Directive (73/23/EEC4) was adopted in 1973. It was later amended5 and 
then codified and replaced by a second Low Voltage Directive (2006/95/EC6) which in turn was 
repealed and replaced by the current Low Voltage Directive 2014/53/EU.  

The  purpose  of  this  evaluation  is  to  analyse  the  performance  of  the  Low  Voltage  Directive 
towards its objectives of facilitating the free movement of electrical equipment across the Union 
and  protecting  consumers'  and  users'  health  and  safety.  The  evaluation  assesses  the  extent  to 
which  the  Directive  is  fit  for  purpose,  hence  continues  to  deliver  effectively,  efficiently  and  at 
minimum cost the intended benefits for consumers and business. 

The evaluation is supported by an external study (hereafter evaluation study)7, commissioned by 
DG  GROW  and  conducted  from  June  2018  to  June  2019.  It  should  be  noted  that  any  data 

1  Directive  2014/35/EU  of  the  European  Parliament  and  of  the  Council  of  26  February  2014  on  the 
harmonisation  of  the  laws  of  the  Member  States  relating  to  the  making  available  on  the  market  of 
electrical equipment designed for use within certain voltage limits (OJ L 96, 29.3.2014, p. 357). 

2  Directive  2014/53/EU  of  the  European  Parliament  and  of  the  Council  of  16  April  2014  on  the 
harmonisation of the laws of the Member States relating to the making available on the market of radio 
equipment and repealing Directive 1999/5/EC (OJ L 153, 22.5.2014, p. 62). 

3  Directive  2014/30/EU  of  the  European  Parliament  and  of  the  Council  of  26 February  2014  on  the 
harmonisation  of  the  laws  of  the  Member  States  relating  to  electromagnetic  compatibility  (OJ  L  96, 
29.3.2014, p. 79). 

4  Council  Directive 73/23/EEC of  19 February 1973  on  the  harmonisation  of  the  laws  of  Member  States 
relating to electrical equipment designed for use within certain voltage limits (Low-voltage Directive), 
available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=LEGISSUM%3Al21015b.  

(safety  of 

5  Council  Directive  93/68/EEC  of  22  July  1993  amending  Directives  87/404/EEC  (simple  pressure 
vessels),  88/378/EEC 
(construction  products),  89/336/EEC 
toys),  89/106/EEC 
(personal  protective 
(electromagnetic  compatibility),  89/392/EEC 
equipment),  90/384/EEC  (non-automatic  weighing  instruments),  90/385/EEC  (active  implantable 
medicinal devices), 90/396/EEC (appliances burning gaseous fuels), 91/263/EEC (telecommunications 
terminal  equipment),  92/42/EEC  (new  hot-water  boilers  fired  with  liquid  or  gaseous  fuels)  and 
73/23/EEC  (electrical  equipment  designed  for  use  within  certain  voltage  limits),  available  at: 
http://data.europa.eu/eli/dir/1993/68/oj.  

(machinery),  89/686/EEC 

6  Directive  2006/95/EC  of  the  European  Parliament  and  of  the  Council  of  12  December  2006  on  the 
harmonisation of the laws of Member States relating to electrical equipment designed for use within 
certain voltage limits, available at: http://data.europa.eu/eli/dir/2006/95/oj. 

7 Study on “Interim evaluation of the low voltage directive 2014/35/EU” by , ECORYS , VVA, published 

on 2020-02-11  
https://op.europa.eu/en/publication-detail/-/publication/48c2118c-4d4d-11ea-aece-
01aa75ed71a1/language-en/format-PDF/source-172841363  

1 

 
 
                                                      
 
 
 
 
 
 
 
presented in this evaluation, which refers to EU or EU Member States, include the states which 
were EU Member States (i.e. EU27 and UK) when the evaluation study was carried out. 

SCOPE OF THE EVALUATION 

The evaluation covers all relevant product categories in the scope of the  LVD (2014/35/EU) in 
relation to the EU, including the UK, the 4 European Free Trade Association (EFTA) countries, 
and Turkey.   

The  evaluation  covers  the  functioning  of  the  Directive,  including  the  processes  involved  in 
transposing,  implementing  and  enforcing  it,  as  well  as  assessment  and  monitoring  procedures. 
The  evaluation  assesses  the  performance  of  the  Directive  according  to  five  criteria:  relevance, 
effectiveness, efficiency, coherence, and EU added value. 

2  BACKGROUND TO THE INTERVENTION 

DESCRIPTION OF THE LOW VOLTAGE DIRECTIVE AND ITS OBJECTIVES  

The scope of the LVD covers electrical equipment with a rated voltage between 50 V and 1000 V 
(alternating current) or between 75 V and 1,500 V (direct current) that is placed on the internal 
market. The LVD has two main objectives.  

Figure 1 – Objectives of the Low Voltage Directive 

Source: Evaluation study 

Firstly,  it  provides  that  electrical  equipment,  within  its  scope,  must  be  compliant  with  the 
necessary  requirements  to  ensure  the  health  and  safety  of  persons,  domestic  animals  and 
property. The  safety objectives cover all risks arising from the use of electrical equipment, not 
just electrical ones, but also other risks such as mechanical or chemical (in particular, emission of 
aggressive substances). They also include health aspects of noise and vibrations, and ergonomic 
aspects as far as ergonomic requirements are necessary to protect against hazards in the sense of 
the LVD. To this end, the economic operators can rely on harmonised standards (the references 
of which have been published in the Official Journal of the EU under the Directive) which, when 
fulfilled  by  the  equipment,  give  a  presumption  of  conformity  with  the  corresponding  safety 
objectives.  

Secondly,  it  aims  to  guarantee  that  compliant  products  can  move  freely  within  the  internal 
market, for the aspects it covers (health and safety), thus ensuring the functioning of the internal 
market.  

2 

 
 
 
 
                                                                                                                                                              
 
Typical example of electrical equipment falling under the LVD are, but not limited to, household 
appliances8 such as television, refrigerator, oven, microwave, toaster, blender, lamps, etc.; cables; 
power supply units; laser equipment; certain components such as fuses, etc. 

Annex  II  to  the  LVD  lists  the  types  of  equipment,  which  are  excluded  from  the  scope  of  the 
LVD.  Moreover,  pursuant  to  the  Radio  Equipment  Directive  (RED)9  and  the  Machinery 
Directive,10 the LVD does not apply to equipment within the scope of those Directives, but the 
safety objectives of the LVD which are up taken by those Directives, apply to that equipment. 

To achieve the objectives of the LVD, the economic operators can rely on: 

-  Harmonised  standards  which  give  a  presumption  of conformity  with  the  corresponding 

safety objectives; 

-  Conformity  assessment  procedure  in  which  the  manufacturer  ensures  and  declares 

conformity of the electrical equipment with the provisions of the LVD ; 

-  Market  surveillance  which  can  monitor  the  compliance  of  a  product  with  the  LVD 

objectives.  

8 The LVD applies only to equipment having no internet function. 

9  DIRECTIVE 2014/53/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 April 
2014 on the harmonisation of the laws of the Member States relating to the making available on the 
market of radio equipment and repealing Directive 1999/5/EC 

10 Directive 2006/42/EC of the European Parliament and of the Council of 17 May 2006 on machinery, and 

amending Directive 95/16/EC (OJ L 157, 9.6.2006, p. 24). 

3 

 
 
                                                      
The figure below (Figure 2) provides an overview of the intervention logic.  

1 

SpecificobjectivesActivities/ actionsGeneral objectivesEnsure internal market for equipment in the scope, by preventing obstacles to the free movement of such equipment Ensure that electrical equipment placed in the EU market provides high level of protection of health and safetyof persons or domestic animals and to propertyOutputsNeeds Supporting the achievement of the full potential of the Internal Market Protecting the health and safety of citizens, animals and property Ensuring harmonisationof rules and procedures  across the EUEnsuring fair competitivenessin the sectorPreventing non-compliant electrical equipment to be placed on the EU marketInputsHarmonised standards for electrical equipment across the EU Essential requirements addressing the safety objectives, covering risks and health aspectsProvision of guidance(Guidelinesfor the application of the  LVD, Papersfrom LVD Electrical Committee and LVD Working Party, Reportsfrom Administrative Cooperation (ADCO)Conformity assessment procedures  must demonstrate that health and safety objectives have been achievedApplication of harmonised standards for presumption of conformity by manufacturers (voluntary)Application of essential requirements addressing the health and safety objectives  by manufacturers Monitoring of application of harmonised standards and conformity assessment procedures by Member States Enforcement mechanisms  at EU level (Electrical Committee and LVD working Party) and in Member States (ADCO)CE markingEU declaration of conformityTechnical documentationExpected results Safetyof products on the EU marketFree circulation in the Internal market pf products in scopeHamonisedimplementation of standards and  procedures across the EUTimely identification and removal of non-compliant products across the EU  
 
 
 
 
PREVIOUS LOW VOLTAGE DIRECTIVES AND CHANGES INTRODUCED BY THE 
CURRENT DIRECTIVE (LVD) 

The first LVD 73/23/EEC, was adopted in 1973, as one of the EU’s first product harmonisation 
directives.  It  introduced  manufacturers’  obligations  to  ensure  that  equipment  placed  on  the 
market is safe, which is still the core of the LVD today. Although the CE  marking did not yet 
exist  at  that  point,  the  first  Low  Voltage  Directive  already  included  provisions  regarding 
conformity declaration and marking.  

In  2006,  Directive  2006/95/EC  replaced  Directive  73/23/EEC,  as  amended  by  Directive 
93/68/EEC on CE marking rules, but the contents of the amended Directive 73/23/EEC were not 
modified. 

In 2008, the horizontal provisions of the New Approach11 were reviewed with the adoption of the 
New Legislative Framework (NLF) i.e. Regulation (EC) 765/200812, Decision No 768/200813 and 
Regulation (EC) 764/200814. The Alignment Package was a term used to describe the process of 
bringing Union harmonisation legislation (i.e. industrial product directives, such as the LVD) up-
to-date  with  the  NLF.  On  29  March  2014,  the  Commission  published  the  recasts  of  eight  CE 
marking  directives,  which  included  the  LVD  (2014/35/EU).  As  a  result,  Directive  2006/95/EC 
was repealed and replaced by the current LVD, Directive 2014/35/EU, which entered into force 
in April 2014 and became applicable as of 20 April 2016. Additionally, the current LVD was also 
aligned with the procedures of the Standardisation Regulation (EU) 1025/2012.   

Thanks to the alignment to the NLF, the current Low Voltage Directive clarifies the definitions 
and  obligations  of  economic  operators,  regulates  the  conformity  assessment  in  further  detail, 
clarifies  the  meaning  of  CE  marking  and  improves  the  procedures  on  market  surveillance. The 
most  significant  changes  are  the  removal,  from  the  market  surveillance  provisions,  of  the 
references to any implication of notified bodies15 for assessing the conformity of products in view 

11 The New Approach to technical harmonisation and standards was introduced in 1985. The key principles 
are: a clear separation between the EU legislation and the European standardization; the EU legislative 
harmonisation  is  limited  to  the  essential  safety  requirements;  the  task  of  drawing  up  the  technical 
specifications  is  entrusted  to  the  standardisation  bodies;  products  manufactured  in  conformity  with 
harmonised standards published in the Official Journal of the EU are presumed to be conformant to the 
essential  requirements;  standards  are  not  mandatory,  they  remain  voluntary.  Alternate  paths  are 
possible; standards must offer a guarantee of quality with regards to the essential requirements of the 
directives;  public  authorities  are  still  responsible  for  the  market  surveillance;  and  safeguard  clauses 
require  the  Member  States  to  take  all  appropriate  measures  to  restrict  placing  on  the  market  or 
withdraw unsafe products from the market. 

12 Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008 setting out 
the  requirements  for  accreditation  and  market  surveillance  relating  to  the  marketing  of  products  and 
repealing Regulation (EEC) No 339/93, available at: http://data.europa.eu/eli/reg/2008/765/oj. 

13 Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a common 
framework  for  the  marketing  of  products,  and  repealing  Council  Decision  93/465/EEC,  available  at: 
http://data.europa.eu/eli/dec/2008/768(1)/oj.  

14 Regulation (EC) No 764/2008 of the European Parliament and of the Council of 9 July 2008 laying down 
procedures relating to the application of certain national technical rules to products lawfully marketed 
in 
at: 
http://data.europa.eu/eli/reg/2008/764/oj.  

repealing  Decision  No 

another  Member  State 

3052/95/EC, 

available 

and 

15  A  notified  body  is  an  organisation  designated  by  an  EU  country  to  assess  the  conformity  of  certain 
products  before  being  placed  on  the  market.  These  bodies  carry  out  tasks  related  to  conformity 

1 

 
 
 
                                                      
 
 
 
of  their  placing  on  the  market  and  the  introduction  of  the  rule  that  the  references  of  the 
harmonised  standards  shall  be  published  in  the  OJEU  under  the  LVD,  in  order  to  grant 
presumption  of  conformity  with  the  corresponding  safety  objectives.  The  current  LVD  did  not 
amend or modify the second LVD’s legal substance with regard to its objectives (e.g. its safety 
objectives  which  remain  unchanged  which,  unlike  in  the  new  legislative  framework,  are  not 
called essential requirements) and main scope (it has only inserted an exclusion on ‘Custom built 
evaluation kits destined for professionals to be used solely at research and development facilities 
for such purposes’).  

As of 16 July 2021, the LVD will apply in conjunction with the market surveillance provisions of 
Regulation (EU) 2019/102016. 

It is in this context that the present evaluation looks at assessing the degree of achievement of the 
original objectives of the LVD (2014/35/EU) as regards to effectiveness, efficiency, coherence, 
relevance, and EU added value. 

3 

IMPLEMENTATION / STATE OF PLAY 

All EU Member States have communicated to the Commission the texts of the main provisions of 
national  law  which  they  adopted  in  the  field  covered  by  the  LVD.    Currently,  there  are  no 
infringement procedures17 in relation to the LVD. 

Member  States  are  responsible  for  appointing  competent  authorities  responsible  for  the 
implementation of the Directive at national level and for ensuring that the Directive is effectively 
enforced  within  their  territories.  As  such,  they  are  also  responsible  for  market  surveillance, 
including penalties. 

RELEVANT BODIES 

Several  specific  bodies  assist  the  Commission  in  managing,  monitoring  and  enforcing  the 
implementation of the LVD:  

The  Committee  on  Electrical  Equipment  was  established  pursuant  to  Article  23  of  the  LVD, 
within the meaning of Regulation (EU) No 182/201118 concerning mechanisms for control by EU 
Member  States  of  the  Commission’s  exercise  of  implementing  powers.  It  consists  of 
representatives from the EU Member States as members, as well as EFTA countries and Turkey, 
as observers. The Commission is required to consult the committee when implementing acts are 

assessment  procedures  set  out  in  the  applicable  legislation,  when  a  third  party  is  required.  The 
European Commission publishes a list of such notified bodies. 

16 Regulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 on market 
surveillance  and  compliance  of  products  and  amending  Directive  2004/42/EC  and  Regulations  (EC) 
No 765/2008 and (EU) No 305/2011 (OJ L 169, 25.6.2019, p. 1). 

17  See  online  database  of 

infringement  decisions:  http://ec.europa.eu/atwork/applying-eu-law/infringements-

proceedings/infringement_decisions/?lang_code=en  

18  Regulation  (EU)  No  182/2011  of  the  European  Parliament  and  of  the  Council  of  16  February  2011 
laying down the rules and general principles concerning mechanisms for control by Member States of 
at: 
the 
http://data.europa.eu/eli/reg/2011/182/oj. 

Commission’s 

implementing 

available 

exercise 

powers, 

of 

2 

 
                                                                                                                                                              
 
 
prepared under the LVD and on any question where the opinion of sectoral experts is required by 
the EU legislation (notably Regulation (EU) No 1025/201219 on European standardisation).  

The LVD Working Party20 is the most frequently used forum to discuss the practical application 
of the Directive at EU level. It is composed of representatives of EU Member States, as members, 
as  well  as  EFTA  countries,  Turkey  and  stakeholders  such  as  standards  makers,  industry 
representatives,  consumers  associations,  etc.,  as  observers.  It  is  organised  and  chaired  by  the 
Commission. 

The LVD AdCo (Administrative Co-operation) is composed of the national market surveillance 
authorities  responsible  with  the  enforcement  of  the  Directive.  It  works  independently  from  the 
Commission.  National  market  authorities  use  this  working  group  for  international  co-operation 
and information exchange.  

GUIDELINES 

Additionally to the above groups, the Guidelines on the application of the LVD21 developed in 
cooperation with all stakeholders represented in the LVD Working Group, is a widely used tool 
that is highly appreciated for facilitating the effective and efficient application of the Directive. 

EUROPEAN STANDARDISATION 

The  European  harmonised  standards  (hENs)  which  give  presumption  of  conformity  to  the 
Directive when published in the Official Journal of the EU (OJEU) underpin the implementation 
of  the  LVD.  These  harmonised  standards  are  developed  by  the  European  standardisation 
organisations (CEN and CENELEC) with the active participation of the industry, consumers and 
workers  representatives.  Harmonised  standard  translate  the  essential  health  and  safety 
requirements (EHSR) into detailed technical specifications for certain types of products.  

4  METHODOLOGY 

DATA COLLECTION AND CONSULTATION STRATEGY 

The evaluation study was conducted from June 2018 to June 2019, with data collection activities 
running until April 2019, as presented in detail in Annex 3. The findings of the study are based 
on a programme of research and analysis, which included the following: 

-  Desk research 

Desk  research  was  a  constant  activity  during  the  whole  study.  It  analysed  relevant 
documentation,  including  Regulations,  Directives,  Communications,  Notices  and  Working 
Documents,  Joint  Market  Surveillance  Actions,  as  well  as  internal  notes  and  minutes,  reports 
from  other  studies,  reviews  and  monitoring  activities  (see  Annex  5).  Database  extracts  from 
Eurostat, the Rapid Alert System for Dangerous Non-Food Products (Safety Gate/RAPEX) and 
from national authorities, etc. were also analysed. 

19 Regulation (EU) No 1025/2012 of the European Parliament and of the  Council of 25 October 2012 on 
European  standardisation,  amending  Council  Directives  89/686/EEC  and  93/15/EEC  and  Directives 
94/9/EC,  94/25/EC,  95/16/EC,  97/23/EC,  98/34/EC,  2004/22/EC,  2007/23/EC,  2009/23/EC  and 
2009/105/EC  of  the  European  Parliament  and  of  the  Council  and  repealing  Council  Decision 
87/95/EEC and Decision No 1673/2006/EC of the European Parliament and of the Council, available 
at: http://data.europa.eu/eli/reg/2012/1025/oj.  

20 Low Voltage Directive Working Party, expert group number: E01342 

21  LVD 2014/35/EU - Guidelines on the application of the directive - August 2018 

3 

 
                                                      
 
- 

Interviews 

A total of 65 interviews were carried out as part of the consultation activities. Different types of 
stakeholders, at both EU and national level, were interviewed. Stakeholders from third countries 
were  also  interviewed  with  the  aim  of  completing  the  understanding  of  legislative  systems  for 
low voltage products in other regions of the world (presented in Annex 5) and possibly spot ‘best 
practices’.  

-  Consultations  

For the evaluation, two online consultations were carried out: a targeted stakeholder survey, with 
differentiated questions per type of stakeholder, and a Public Consultation (Public Consultation) 
with one single set of questions for all respondents.  

o  Targeted stakeholder survey 

The stakeholder survey was launched on 4 December 2018 and addressed to the sector’s relevant 
stakeholders.  Its  initial  closure  date  was  planned  on  15  January  2019,  but  to  maximise  the 
response rate over the holiday period, it was extended until 31 January 2019. 

In  total,  221  respondents  answered  the  survey.  Out  of  these,  116  were  manufacturers,  10  were 
importers  and  distributors,  13  were  National  Authorities  including  market  surveillance 
authorities,  40  were  business  associations,  4  were  consumer  organisations,  and  38  reported  as 
belonging  to  “others”  group.  This  last  category  included,  among  others,  testing  and 
standardisation  organisations,  notification  bodies,  consultancies,  academic  and  educational 
organisations. 

o  Public Consultation 

In line with the Better Regulation Guidelines, a Public Consultation was launched on 10 January 
2019, for 12 weeks. The Public Consultation questionnaire was addressed to all EU citizens.  

The  Public  Consultation  gathered  93  replies  across  17  Member  States.  The  highest  number  of 
replies came from Germany and the UK.  

-  Workshop 

A workshop was organised on 8 February 2019 in Brussels during the LVD Working Party (39 
members  participated),  to  discuss  the  preliminary  findings  about  the  three  following  topics: 
understanding of the LVD, implementation of the LVD, and, enforcement of the LVD. 

DATA ANALYSIS METHODOLOGY 

Following the data collection activities, data triangulation was conducted where possible, in order 
to map different inputs from various sources against each other, and deduct findings. Due to the 
lack  of  existing  evidence,  notably  quantitative  data,  on  the  actual  performance  of  the  LVD  as 
regards the evaluation criteria, this evaluation largely draws on the findings of the interviews and 
workshop carried out as part of the evaluation study. The opinions of the different stakeholders’ 
groups  have  been  taken  into  account  (including  under-represented  stakeholder  groups  such  as 
SMEs  and  consumers)  and  cross-checked  against  each  other.  Further,  the  targeted  stakeholder 
survey as well as the Public Consultation results – though not statistically representative  - were 
leveraged  to  validate  or  challenge  the  trends  identified  through  the  previously  mentioned  data 
collection activities.  

4 

 
STATISTICAL DATA ON PRODUCTS IN THE SCOPE OF THE LVD  

A challenge for the data collection and the analysis is that low voltage products are not a defined 
sector  in  the  industry  and  are  also  not  logged  as  a  separate  group  of  products  in  statistical 
databases.  

Consequently, assumptions were needed in order to define the low voltage sector in relation to 
market  data.  The  manufactured  products  described  in  the  NACE  categories  contain  products 
falling both within and outside the scope of the LVD. Therefore, the more detailed Prodcom-level 
product list for each of these NACE categories were applied to specific criteria in order to define 
whether  each  product  category  fall  within  the  scope  of  the  LVD.  To  fall  in  the  scope  of  the 
Directive, a product category has to comply with the following criteria:  

  The product refers to electrical equipment; 

  The product falls within the voltage limits set by the Directive; 

  The product is not part of the exceptions included in the Directive; and 

  The  product  that  is  not  excluded  from  the  LVD  because  it  falls  under  other  relevant 

Directives (such as the Radio Equipment Directive or the Machinery Directive). 

Based  on  those  criteria,  188  Prodcom-level  products  under  9  NACE  Rev.  2  categories  are 
potentially  falling  within  the  scope  of  the  LVD.  However,  it  is  not  possible  to  have  a  clear 
conclusion for each product category as they consist of a mix of products. Hence a ‘minimum’ 
range of products that are in the scope of the LVD, and an ‘additional’ range of products that can 
be either within or outside the scope of the LVD. These two categories establish the ‘maximum’ 
range of products that can be covered by the LVD. 

Data  on  dangerous  products  falling  under  the  LVD  was  collected  through  the  Rapid  Alert 
System for dangerous non-food products (Safety Gate/RAPEX). As Safety Gate/RAPEX uses 
different categorisation of products, it was not possible to link the products immediately to the 
product  groups  used  in  the  economic  analysis  of  the  evaluation  study.  However,  the  most 
commonly  reported  Safety  Gate/RAPEX  category  for  which  reference  to  non-compliance  with 
the  LVD  is  made  is  electrical  appliances  and  equipment  (55%  of  such  alerts  over  2005-2018), 
which  includes  equipment  such  as  small  kitchen  appliances  and  home  electronics,  cables, 
chargers  and  adapters,  and  hand  tools.  76%  of  the  Safety  Gate/RAPEX  measures  on  products 
covered by the requirements of the products under the Directive reported originated from China 
across the years. 

COST-BENEFIT ANALYSIS  

It should be noted that stakeholders consulted provided very limited quantitative data on the costs 
and the benefits of the LVD during the evaluation study. There are two main reasons to that: 

-  The  LVD  sets  few  obligations  directly  for  stakeholders  and  provides  a  framework  for 
good conduct though the referral to other instruments (Market Surveillance, CE Marking, 
Conformity Assessment, Harmonised Standards).  

- 

In addition, the LVD is now fully integrated in the national regulatory framework and it 
is challenging for stakeholders to assess (quantitatively) the costs and benefits that arise 
from the application of the Directive. 

Detailed  information  on  statistical  data  used  for  products  within  the  scope  of  the  LVD,  Safety 
Gate/RAPEX and cost and benefits data is provided in Annex 3. 

5 

 
5  ANALYSIS OF THE LVD MARKET  

As stated in section “Statistical data on products in the scope of the LVD”, the assumptions for 
the products data provided allow us to present a ‘minimum’ range of products that are within the 
scope of the LVD, and an ‘additional’ range of products that can be either within or outside the 
scope of the LVD. Together, these categories constitute the ‘maximum’ range of products that are 
covered by the LVD.  

Most  data  presented  in  this  section  cover  the  maximum  range  of  the  low  voltage  market 
(minimum and additional products). 

ECONOMIC IMPORTANCE IN THE EU   

The  minimum  range  of  products  on  low  voltage  market  represents  approximately  1%  of  the 
European  manufacturing  sector.  The  additional  range  of  products  on  low  voltage  market 
represents approximately 2.7%. Both together result in 3.7% of maximum range of products for a 
total  amounted  of  EUR  206,067  million  in  2017,  with  the  most  significant  NACE  industry 
categories being that of motors, generators, transformers and electricity distribution and control 
apparatus  followed  by  domestic  appliances  and  equipment  for  motor  vehicles.  With  regards  to 
low voltage production within each industry, those that have the highest percentage of products 
falling  under  the  LVD  are  electrical  and  electronic  equipment  for  motor  vehicles,  electric 
domestic appliances and other electric equipment. Germany has the largest average of the yearly 
production values over the past five years from EU Member States22.  

Figure  4  shows  the  average  of  the  yearly  production  values  over  the  past  five  years  across 
different  Member  States.  A  five-year  average  is  used,  as  annual  data  could  give  an  inaccurate 
picture  because  there  can  be  significant  fluctuations  in  production  values,  largely  due  to  data 
availability.23 

Figure 3 – Member State annual average production of Low Voltage product group (annual average 2012-
2017) 

Source: Evaluation study 

22  To  illustrate,  63  of  the  188  products  of  the  low  voltage  products  (maximum  range)  were  reported  as 

confidential for Germany in 2017. 

23  It  should  be  noted  that  product  level  data  are  not  complete,  as  a  large  share  of  product-level  data  is 
reported as confidential.36 Therefore, one should be careful in drawing strong conclusions from these 
data. 

6 

 
 
                                                      
Low  voltage  product  manufacturing  has  grown  at  a  slightly  lower  rate  than  the  overall  EU 
manufacturing  industry.  The  maximum  low  voltage  production  (minimum  and  additional) 
dropped from representing 5.0% of EU manufacturing in 1995 to approximately 3.8% in 2017. 
However, it should be noted that product level data are not complete, as a large share of product-
level data is reported as confidential. 

INTRA- AND EXTRA-EU TRADE IN LOW VOLTAGE PRODUCTS 

In  2017,  intra-EU  trade  was  larger  than  extra-EU  trade  and  the  EU  imported  more  than  it 
exported. Table 1 shows the levels of EU trade of low voltage products with EU Member States 
and countries outside of the EU (for readability referred to as intra- and extra- EU).  

Table 1 – Intra and extra-EU trade maximum and minimum range (million euro), 2018 

Intra-EU 

Extra-EU 

Minimum  range 
of LVD 

Maximum  range 
of LVD 

40,606 

203,059 

Minimum  range 
of LVD 
33,972 
19,735 

Maximum  range 
of LVD 
101,825 
128,874 

Exports 
Imports 

Source: Evaluation study calculations based on Easy Comext 

EU exports in low voltage products have always been higher in the intra-EU market as compared 
to  the  extra-EU  market.  The  value  of  trade  in  low  voltage  products  between  the  EU  Member 
States has fluctuated between 60% and 70% of total low voltage trade of the EU Member States 
over the past decades.24 While both types of exports have been growing at similar rates, intra-EU 
exports have grown a bit more rapidly over the past 5 years, gaining in importance compared to 
exports to extra-EU countries.  

The product category in trade with the highest values is that of machines for the reception and 
conversion  of  voice  images  or  data  (including  switching  and  routing  apparatus  but  excluding 
telephones for wireless networks) as well as apparatus for electric control or the distribution of 
electricity, electric conductors and switches. 

Intra  EU  trade  shows  large  values for  electrical apparatus  for  switching  or  protecting  electrical 
circuits, or for making connections to or in electrical circuits, e.g., switches, relays, fuses, surge 
suppressors. 

Extra EU exports is strong on electric motors and generators (excl. generating sets) and electric 
transformers,  whereas  extra-EU  imports  have  larger  values  for  products  with  more  domestic 
purposes, such as electric heaters, hairdryers, hand dryers and electric smoothing irons.  

For imports, the larger intra-EU flows also holds, though the difference in trends between intra 
and extra- EU imports in recent years has been less pronounced. 

24 As in the entire market analysis section, this is an estimation and based on a database with several gaps. 
The  change  in  2005  seen  in  the  graph,  for  example,  is  due  to  previously  unavailable  trade  data  for 
some low voltage products becoming available, and not due to rapidly increasing exports.  

7 

 
 
 
                                                      
 
 
Figure 4 - Intra- and extra-EU exports of LVD products (maximum range), 2000-2018 

Source: Evaluation study calculations based on Easy Comext.  

Figure 5 - Intra and extra-EU imports of LVD products (maximum range), 2000-2018 

Source: Evaluation study calculations based on Easy Comext 

The  above  figures  show  the  trends  for  the  maximum  range  of  low  voltage  products.  When 
disaggregating  these  values  per  product  categories,  the  ‘minimum’  low  voltage  category  is 
relatively  more  important  in  EU  exports  to  the rest  of  the  world than  in  its imports  from  other 
countries. 

Since 2013, imports into the EU have increased much faster than EU exports to the rest of the 
world, therefore increasing the trade deficit. 

Regarding  trading  partners  outside  the  EU,  China  is  by  far  the  largest  import  partner.  Export 
partners are more varied, with the US accounting for the largest share of exports. Approximately 
45% of extra-EU imports in 2018 came from China, which is the result of a significant growth in 
Chinese low voltage imports that started in the early 00s and have been growing exponentially 
since 2007. 

8 

050000100000150000200000250000200720082009201020112012201320142015201620172018Million EUROIntra-EU exportsExtra-EU exports050000100000150000200000250000200720082009201020112012201320142015201620172018Million EUROIntra-EU importsExtra-EU imports 
 
 
CONSUMPTION OF LOW VOLTAGE PRODUCTS  

Over the last 20 years, European consumption25 of electronic equipment has steadily increased. 
Although in 2008 consumption of products under the LVD showed a decrease as a result of the 
economic  crisis,  consumption  has  recovered  after  and  was  back  on  pre-crisis  levels  by  2016. 
However,  values  should  be  taking  as  an  approximation,  both  due  to  missing  values  for  certain 
products  and  years  and  due  to  the  combination  of  different  statistical  categories  (Prodcom  for 
production and HS for trade).  

Additional figures supporting this section “Analysis of the market” can be found in Annex 4. 

6  TRENDS AND DEVELOPMENTS WITHIN THE LOW VOLTAGE MARKET 

Main  trends  and  developments  identified  within  the  low  voltage  market  are  technological 
innovations and e-commerce. 

TECHNOLOGICAL INNOVATIONS: CONNECTED SYSTEMS AND THE INTERNET OF 
THINGS  

The  scope  of  the  LVD  and  the  products  it  covers  are  affected  significantly  by  the  increasing 
importance  of  the  Internet  of  Things  (IoT),  where  everyday  products  are  embedded  with 
computing  devices  allowing  them  to  wirelessly  send  and  receive  data.  Consumer  electronics 
accounts  for  one  of  the  largest  segments  of  the  IoT  market.  The  surge  of  “smart  homes”  with 
multiple purposes (energy saving, replenishing, remote control, etc.) is expected to keep growing. 
The  expected  average  annual  growth  rate  of  smart  appliance  users  in  Europe  is  33%  for  the 
period of 2016-202226. Statista27, a provider of market and consumer data, estimated household 
penetration of smart homes in Europe at 10.9% for 2018, expecting this value to rise to 22.5% by 
2023.  This means that almost a fourth of all European households is expected to have at least 
one  type  of  home  automation  functionality  in  place  –  be  that  in  appliances,  entertainment 
systems,  temperature  control  or  lighting.  These  were  the  growth  rates  expected  before  the 
apparition of Covid-19 crisis. 

Developments  in  IoT  affects  the  coherence  between  the  LVD  and  the  RED,  which  is  further 
analysed in chapter 7.4. 

E-COMMERCE  

E-commerce  continues  to  grow.  Seven  in  ten  European  online  shoppers  bought  items  from 
retailers  outside  their  home  country  in  201728  and  EU  enterprises  turnover  from  e-commerce 
reached an average of 18% of their total sales in the same year.29  

The  main  trends  reveal  that  purchasers  prefer  to  buy  low  voltage  products  online  and  in 
electric/electronic stores, while second hand transactions are the least common shopping  mean. 
Around 77% of the shopping in electric stores happened in the country of origin of the purchasers 
and 18% in another Member States.  

25 Consumption levels calculated as Production level + (Extra-EU imports – Extra-EU exports). 
26 APPLiA, The Home Appliance Industry in Europe 2017-2016 (2018)  

27 Statista, Smart Home 

28 UPS Pulse of the European Shopper - ComScore Survey 

29 Eurostat, Value of ecommerce sales [isoc_ec_evaln2]. 

9 

 
 
                                                      
 
 
 
 
Concerning  online  shopping,  before  the  Covid-19  crisis,  nearly  57%  of  the  products  were 
purchased in the country of origin, 25% in another European country and 18% in another country 
outside the European Union. Overall, the participants seem to prefer buying low voltage products 
in  their  countries  or  at  least  in  the  European  Union.  The  most  quoted  countries  for  the  extra-
European countries were the Asian ones, China in particular, and the US.  

E-commerce  changes  the  way  consumers  shop  on  a  large  scale,  with  40%  of  consumers 
preferring  to  buy  consumer  electronics  online.30  This  was  also  confirmed  by  the  Public 
Consultation (Public Consultation) carried as part of evaluation study.  

7  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

FINDINGS IN RELATION TO THE EFFECTIVENESS OF THE DIRECTIVE 

This  section  presents  the  findings  on  the  effectiveness  of  the  LVD  at  the  level  of  its  core 
objectives. 

Regarding the Directive’s contribution to the internal market, notably about the difficulties to 
apply  the  LVD  in  practice,  85  out  of  116  manufacturers  that  responded  to  the  stakeholder 
survey31  declare  facing  no  issues  or  some  issues  to  a  limited  extent.  Out  of  the  27  economic 
operators  having  reported  facing  issues  to  some  or  great  extent,  18  provided  further  insights 
through  comments.  The  remaining  4  respondents  didn’t  know  if  applying  the  LVD  induced 
difficulties. Overall, the main concerns are related to the overlaps with other legislation such as 
the RED or the MD. This statement is valid irrespective of the size of the businesses as presented 
in the figure  below.  Similarly,  the  majority  of  manufacturers (90  out of 116)  reported  no  issue 
related to the cross-border implementation of the Directive. 

Figure 6 - Stakeholder survey/Manufacturers Q.9: "To what extent do you experience difficulties 
in applying the LVD?" 

Source: Stakeholder survey, evaluation study 

The  stakeholder  survey  provides  a  positive  feedback  relating  to  LVD’s  contribution  to  a  well-
functioning internal market. 9 out of 12 national authorities having replied to the survey indicated 
that  the  LVD  facilitates  the  functioning  of  the  internal  market.  Similarly,  the  four  consumer 
organisations  also  replied positively  to  LVD’s  contribution  to  intra-EU  trades.  The  majority  of 
consulted  manufacturers,  importers  and  distributors  having  taken  part  to  the  survey  share  the 
opinion that the  Directive was  successful in harmonising  the  rules  and requirements  within the 
Member  States  and  therefore,  the  LVD  facilitates  the  free  movement  of  products  in  its  scope 
across the EU. Importers and distributors that replied to the survey also reported no significant 
issues related the LVD when importing/distributing products within the EU.  

30 PWC, Global Consumer Insight Survey (2018). 
31 Annex 5. 

10 

 
 
                                                      
Furthermore,  90  out  of  the  116  manufacturers  reported  that  the  LVD  facilitated  intra-EU 
exchanges to at least some extent, with the majority (69) being satisfied to a great extent; these 
opinions  are  aligned  across  SMEs  and  large  corporations.  Out  of  the  116  manufacturer 
respondents, only four considered that the LVD did not facilitate EU trade in any way. 

Figure  7  –  Q10  Manufacturers:  “to  what  extend  do  you  think  the  LVD  facilitates  intra-EU 
exchanges. 

Source: Evaluation study, Stakeholder survey 

The impact of extra-EU competitors reaching their consumers via online sales may be considered 
as a factor undermining the achievements of the LVD related to fair competition. Indeed, through 
e-commerce, consumers receive products directly (at home) meaning these do not transit by the 
shelves  of  stores  within  the  internal  market,  and  therefore,  this  business  model  might  be 
disruptive of the usual market surveillance inspections. 

E-commerce changes how businesses market products, where products are sourced from and the 
distribution channels. The imported products must comply with Union harmonisation legislation 
on products, as products offered for sale online to EU consumers are considered as being placed 
on  the  EU  market.  Challenges  still  remain  related  to  all  players  in  the  process,  including 
economic operators, surveillance authorities and consumers. Issues are: 

  An increased number of non-EU economic operators active in the EU and the difficulty 

of tracing them; 

  A  lack  of  physical  access  to  the  products  on  the  side  of  national  market  authorities 
making it difficult to sample products or conduct risk assessments (e.g. not all MS can 
purchase online items);  

  A lack of awareness on the side of consumers about product compliance online.  

Some steps are being taken by the Commission for an increased clarity of e-commerce rules32 but 
challenges  remain  in  particular  related  to  market  surveillance.  Market  surveillance  authorities 
have – to various degrees - started developing capacities and tools to help market surveillance for 
products sold online, but have not yet caught up with this fast-evolving sector. Additionally, the 
Goods Package33 communication was initiated in 2017 with the aim to reinforce trust in the single 

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

published: 

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

33 The Goods Package:  

11 

 
 
                                                      
 
 
market and address the weaknesses of the single market for goods that relates to the enforcement 
of EU harmonised product safety rules and that relates to products (sold online or offline) that do 
not fall under harmonised EU product safety rules, or only fall partially under such rules. 

Market  surveillance  for  the  LVD  has  been  highlighted  as  a  key  issue  regarding  the 
implementation  and enforcement  of  the  LVD and affected the  fairness  of  LVD with  regards to 
EU  enterprises  within  the  internal  market.    It  was  mentioned  by  both  companies  and  national 
authorities interviewed that at the moment, (compliant) EU enterprises did not compete on a level 
playing field with extra-EU competitors, especially those active on e-commerce platforms. Extra-
EU  competitors  faced  fewer  deterrents  to  incompliance  than  (compliant)  EU  enterprises,  and 
therefore, were able to offer similar products at cheaper prices on the EU market.  

As regards the European harmonised standards, which are outside the scope of this evaluation, all 
types  of  stakeholder  groups  consulted  confirmed  that  standardisation  is  an  effective  means  to 
ensure  the  adaptability  of  the  Directive  to  market  trends,  including  technological  innovation. 
Harmonised  standards  are  implemented  at  national-level  and  entail  the  withdrawal  of  any 
conflicting ones. This transposition at national level therefore clearly contributes to the removal 
of barriers to trade within the single internal market. This was also confirmed by the economic 
operators having replied to the survey who highlighted the positive effects of standardisation on 
the internal market.34  

To analyse the extent to which the Directive contributed to health and safety, the consultations 
data  as  well  as  available  data  from  Safety  Gate/RAPEX  was  used,  see  Annex  3  for  detailed 
explanation.  Opinions  from  the  stakeholders  and  limitations  of  the  economic  data  were  also 
considered.  Additionally,  the  reports  for  Coordinated  Activities  on  the  Safety  of  Products  and 
Joint Market Surveillance Activities for LVD products were used. 

The consultations data indicated that the majority of all respondent groups, including 9 out of 
12 authorities, considered the main benefits deriving from the LVD related to health and safety 
protection to be ‘high’. Similarly, 3 out of 4 consumer associations having replied to the survey 
reported  that  the  LVD  had  improved  the  safety  of  the  low  voltage  products  available  on  the 
market at least to ‘some extent’. Regarding economic operators, 18 out of 26 SMEs reported an 
improvement  in  the  safety  of  electrical  products  thanks  to  the  LVD  to  a  “great”  or  at  least  to 
“some” extent. The figure was even higher for large companies (77 out of 90).  

Importers and distributors appeared to agree on the high guarantee of safety ensured by the LVD 
provisions with manufacturers though to a lesser extent.  

During the Public Consultation, 24 out of 93 respondents35 affirmed they had been involved in a 
risky situation with an LVD product. All the 24 individuals that replied positively added detailed 
descriptions  of  the  dangerous  situation.  The  dangerous  products  were  various,  such  as  toys, 
electric kitchen utensils, adaptors, etc. Situations in which instructions were not included or the 
CE marking was missing were also described.  Following the dangerous situation, 10 consumers 
decided  to  contact  the  seller  of  the  product,  9  consumers  decided  to  contact  the  economic 
operator specified in the user’s manual, 7 to not contact anyone and 7 to contact the authorities. 
Only 1 individual contacted a consumer association. 

https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=COM%3A2017%3A787%3AFIN 
34Section 

https://op.europa.eu/en/publication-detail/-/publication/48c2118c-4d4d-11ea-aece-

01aa75ed71a1/language-en   

35 The Public Consultation did not allow to differentiate the respondents per type of stakeholder. 

12 

 
                                                                                                                                                              
 
Hence, while the perception of both EU Member States authorities and consumer organisations is 
rather  positive  about  the  level  of  safety  of  low  voltage  products  in  the  EU,  there  is  still  quite 
some room for improvement in this area. 

National  authorities  participating  in  the  stakeholder  survey36  were  also  asked  to  provide  some 
information from their perspective on the numbers of non-conforming equipment. According to 
them, ‘electric lighting equipment’ was the category most commonly found to be non-compliant, 
followed by electric domestic appliances and consumer electronics. Figure 17 below displays the 
numbers in more detail.  

Figure 8 – Q9 Authorities: “What types of LVD equipment are most commonly found to be non-
compliant 

Source: Evaluation study, stakeholder survey 

It  should  also  be  noted  that  in  Safety  Gate/RAPEX  the  most  commonly  reported  category  of 
equipment is electrical appliances and equipment (55% of alerts over 2005-2018), which includes 
equipment such as small kitchen appliances and home electronics, cables, chargers and adapters, 
and  hand  tools.  In  the  same  vein,  according  to  the  authorities  having  replied  to  the  survey, 
electric  lighting  equipment,  electric  domestic  appliances  and  consumer  electronics  are  also  the 
items most commonly recalled from the market. 

Harmonised standards providing presumption of conformity have been widely reported as being 
the  preferred  method  for  ensuring  the  compliance  of  electrical  equipment,  both  in  quantitative 
(i.e.  it  is  the  most  used)  and  qualitative  (i.e.  it  is  the  most  preferable)  terms.  This  was 
unanimously  underlined  by  all  types  of  stakeholders  consulted  as  part  of  the  study37,  including 
consumer  organisations,  national  authorities,  business  associations  and  economic  operators, 
including standardisation bodies. All types of stakeholders highlighted the capacity of standards 
to  ensure  the  convergence,  throughout  the  EU,  of  state-of-the-art  practices  guaranteeing  the 
safety  of  low  voltage  products,  notably  by  formalising  the  essential  safety  requirements  of  the 
Directive that may be considered very generic and succinct. 

During the interviews carried out with the 38 business-related stakeholders consulted as part of 
this evaluation, standards (mostly harmonised and international) were unanimously mentioned as 
being the most leveraged means for economic operators to manufacture compliant products. The 
benefits linked to the presumption of conformity offered by the use of standards was considered 

36 Only 13 national authorities took part to the stakeholder survey. 

37https://op.europa.eu/en/publication-detail/-/publication/48c2118c-4d4d-11ea-aece-

01aa75ed71a1/language-en  

13 

 
 
                                                      
to strongly outweigh their economic cost38. Indeed, it has been reported by economic operators, 
industry  associations  and  standardisation  bodies  that  deviations  from  standards  occurred  very 
rarely. Industry associations actually mentioned there was an implicit rule in the sector: ‘if there 
is a standard, use it’. 

Deviations from standards may happen particularly when a product is very specific or new to the 
market.  In  such  cases,  manufacturers  interviewed  report  that  existing  standards  were  used  as 
‘inspiration’ to the extent possible in order to leverage ‘best practices’. This again underlines the 
importance  of  the  voluntary  characteristic  of  standards  with  regards  to  innovation  and  new 
product development. 

In the same vein, the 116 manufacturers having replied to the stakeholder survey, highlighted a 
number of benefits related to the use of standards. These included namely: ensuring the safety of 
products (48x39), providing a level playing field in the EU (41x), allowing for the simplification 
and  easier  interpretation  of  the  legislation  (18x),  enhancing  the  Internal  Market  and  extra-EU 
trade  (15x)  and  reducing  liability  risks  (1x).  Some  manufacturers  commented  that  the  LVD  is 
“Defining clear & detailed rules for certain product categories to enable a level playing field in 
the  common  market”  and  also  “A  simple  directive  and  well-designed  standards,  drafted  by 
experts, creates safe products and a level playing field”. 

Figure  9  –  Manufacturers  Q22:  “What  do  you  think  are  the  main  benefits  deriving  from 
standardisation for the LVD speciality?” 

Source: Evaluation study, stakeholder survey 

The  consumer  organisations  having  replied  to  the  survey  indicated  the  opportunity  to  play  an 
active role in setting standards, as well as to timely modify standards to ensure the safety levels 
required by the Directive are reached, as the highly-ranked benefits. 

Based  on  the  national-level  interviews,  the  stakeholder  survey  and  the  LVD  Working  Party 
Workshop, it appeared that overall, the current conformity assessment procedure (Module A, as 
provided  by  Annex  III  of  the  Directive)  was  rather  positively  regarded  and  considered  to  fulfil 
expectations  related  to  ensuring  safety  of  LVD  products  in  a  flexible  and  cost-effective  way. 
Manufacturers  considered  themselves  to  be  best  placed  to  assess  the  risks  related  to  their 
electrical  equipment;  for  them  their  internal  production  control  was  effective  and  sufficient  to 
ensure  the  safety.  Opinions  of  national  authorities  and  consumer  organisations  were  more 
nuanced.  In  particular  3  out  of  4  consumers’  organisation  stated  that  conformity  assessment 
procedures guarantee safety of electrical products only to “some extent”. 

38 The overall costs (and benefits) of the Directive will be discussed in detail in further section 

39 Number of times a reply corresponding to the benefit was provided by the responding manufacturer. 

14 

 
 
                                                      
8  out  of  11  market  surveillance  authorities  having  replied  to  the  survey  considered  Module  A 
(which  specifies  the  elements  that  the  EU  declaration  of  conformity  shall  contain)  as  safety-
enabling to some or to a great extent. Comments received included notably the following notes 
from market surveillance authorities: 

 

 

 

‘limited  extent’:  “Manufacturers  (China!)  do  not  always  follow  these  procedures.  Too 
complex? Too expensive?” 

‘limited  extent’:  “Conformity  assessment  could  be  according  to  the  risks  the  products 
present - similar to Personal Protective Equipment legislation” 

‘limited extent’: “Modules B and H of the conformity assessment procedures should be 
included  in  the  LVD  Directive,  because  there  are  safety  aspects  involved  which  come 
with a higher risk profile.” 

Figure  10  –  Stakeholder  survey:  “To  what  extend  do  you  think  that  the  tool  of  the  conformity 
assessment  procedures,  as  provided  by  the  LVD  2014/35/EU,  is  sufficient  and  appropriate  to 
guarantee the safety of electrical products?” 

Source: Evaluation study, stakeholder survey 

More diverging views were expressed for the absence of the Notified Bodies. Those views were 
presented  in  the  stakeholder  survey  as  highlighted  in  the  figure  below.  Overall,  very  few 
manufacturers, consumer organisations, and business associations interviewed (≤≈25%) estimate 
that the absence of notified bodies has a negative impact on the safety of products. This opinion 
is bigger among importers, distributors, and national authorities (between 50 and 60%). Only one 
consumer organisation stated that the removal of Notified Bodies had a strong negative impact on 
safety  (whereas the  other  three  having  replied to  the survey  did  not  have  any  opinion  on  this). 
National authorities having replied to the survey had  the most negative view of  all stakeholder 
categories:  none  of  them  reported  a  “somewhat  positive”  or  “positive  impact”  related  to  the 
absence  of  Notified  Bodies,  whereas  eight  out  of twelve  considered their removal  as  having  at 
least a ‘somewhat negative’ impact. Unfortunately, none of the stakeholders expressing negative 
opinions in the stakeholder survey provided a comment to better explain their perspectives. 

Figure 11  –  Stakeholder  survey  Q14:  “Since  the  LVD  2014/35/EU,  the  notified  bodies  are  not 
anymore part of the procedure. What do you think is the effect of the current absence of notified 
bodies concerning safety of products?” 

15 

 
 
Source: Evaluation study, stakeholder survey 

Consumer organisations present at the Low Voltage Working Party Workshop (and interviewed 
as part of other data collection efforts) welcomed the current conformity assessment procedure, 
however, some highlighted that in order to further enhance the current level of safety in the EU 
market, a Module B such as existing for the EMCD, involving a Notified Body, could be made 
available  and/or  in  certain  instances  mandatory  under  the  Directive,  as  for  example  proposed 
below.  This  was  also  in  line  with  the  comments  received  from  national  authorities  outlined 
above. 

The underlying idea is that (1) some (new/innovative) products may still pose a significant threat 
to end-users and the product should therefore be cleared by a third party organisation rather than 
the manufacturer itself, and (2) that some economic operators, including SMEs (also supported 
by two national authorities present at the workshop), may be willing to de facto have recourse to 
Module  B  for  all  types  of  products,  regardless  of  the  risks  they  may  represent,  as  they  would 
rather rely on the expertise of a Notified Body in conducting the actual conformity assessment. In 
this  second  case,  Notified  Bodies  are  seen  as  a  source  of  support  and  guidance  for  SMEs 
struggling  with  the  conformity  assessment  procedure,  or  in  cases  of  conflicts  with  Market 
Surveillance Authorities. 

Such  supportive  role  was  also  confirmed  as  beneficial  through  the  stakeholder  survey  by 
manufacturing SMEs, importers and distributors. In particular, it was mentioned that for certain 
SMEs, it might be difficult to have the required technical expertise to demonstrate compliance, 
especially  when  developing  innovative  products  which  require  a  mix  of  different  technical 
requirements.  Further,  even  though  there  was  not  much  information  and  consensus  on  the  real 
impact  of  the  provision  (and  how  much  it  is  strictly  perceived  as  a  “collateral  effect”  of  the 
LVD), importers and distributors seemed to be more worried about the impact that the absence of 
notified  bodies  might  have  had  on  the  safety  of  products  than  on  the  manufacturers,  with  5 
respondents reporting a “somewhat negative impact”. On the other hand, this provision was seen 
as a possibility for the industry to reduce costs. 

Figure  12  –  Manufacturers  Q14:  “Since  the  LVD  2014/35/EU,  the  notified  bodies  are  not 
anymore part of the procedure. What do you think of the effect of the current absence of notified 
bodies?” 

16 

 
 
Source: Evaluation study, stakeholder survey 

Figure 13 – Importers and distributors Q15: “Since the LVD 2014/35/EU, the notified bodies are 
not  anymore  part  of  the  procedure.  What  do  you  think  of  the  effect  of  the  current  absence  of 
notified bodies?” 

Source: Evaluation study, stakeholder survey 

For all stakeholder groups consulted (including national authorities, consumer organisations and 
economic operators) the majority of respondents and/or interviewees presented positive feedback 
as regards the LVD’s contribution to safety of electrical equipment in the EU market. However, 
some improvement opportunities regarding practical features of the LVD were mentioned across 
all stakeholder groups, which would allow to further improve the safety of low voltage products 
made available in the internal market:  

17 

 
 
 
All types of stakeholders noted that within the conformity assessment procedure (Module A), it 
may not always be clear for economic operators when there is a need for risk assessment and how 
to carry it out, which can compromise its implementation. In addition, some stakeholders, notably 
consumer  organisations,  may  wonder  whether  all  products  should  have  the  same  procedure,  or 
whether a distinction between risk-levels (e.g. the current self-certification for low-risk products 
and third-party certification for products with higher risks) would be more appropriate to prevent 
accidents. Example40 of such approach below: 

  For products with low to medium risk levels, economic operators would be left with the 
choice of module A or B, as products in this category would not pose a serious and/or life 
threatening risk for consumers in any of their intended or reasonably foreseeable use. 

  For products with high risk levels, economic operators would have to use Module B only, 
as products in this category may pose a serious and/or life threatening risk for consumers 
in some of their intended or reasonably foreseeable use. 

Such separation and list between medium risk and high risk products are not currently part of the 
LVD and it might make little sense to go in that direction.  

As  underlined  by  EU  Member  States  authorities,  further  analysis  of  the  actual  need  to  include 
Notified  Bodies  in  the  conformity  assessment  process  as  well  as  of  the  actual  impacts  of  such 
inclusion should be carried out in order to be able to conclude with precision on this matter. 

Market  surveillance  data  for  LVD  has  been  highlighted  as  a  key  issue  regarding  the 
implementation  and  enforcement  of  the  LVD,  having  impacts  on  both  core  objectives.  It  was 
noted  that  while  in  some  countries  the  process  works  very  well,  and  in  good  cooperation  with 
economic operators, inconsistency across the EU was a challenge. 

Variances  in  market  surveillance  intensity  and  practices,  was  considered  by  some  national 
authorities  to  create  ‘markets  within  the  internal  market’,  with  some  economic  operators 
choosing to go for countries where market surveillance activities were considered less stringent.  

The main issues for national market surveillance authorities were the lack of budget and adequate 
resources; limited  administrative  and  legal  capacity;  lack  of  cooperation  and  communication at 
intra-EU  borders  and  with  customer  authorities,  and  difficulty  intercepting  non-compliant 
products entering the market from outside the EU.  

Overall results of market surveillance activities within the EU Internal single market, showed that 
58% of products evaluated were found uncompliant41. However, it should be noted, that due to 
limited resources, products actually tested by market surveillance authorities were those that were 
already suspected as being dangerous.  

Due  to  these  reasons,  main  LVD  objectives  and  expected  results  are  likely  to  be  affected,  in 
particular safety of the products sold, as not all non-conforming products can be intercepted on 
time on the ‘’output’’ end of the process; and fairness of LVD internal market, as, according to 
opinions gathered for the evaluation study, compliant EU enterprises do not compete on a level 
playing field with extra-EU competitors, especially on e-Commerce platforms.  

40Section 

5.1.2.3 

https://op.europa.eu/en/publication-detail/-/publication/48c2118c-4d4d-11ea-aece-

01aa75ed71a1/language-en  

41European  Commission.  (2017).  Safe  products  in  the  EU  Single  Market:  Commission  acts  to  reinforce 
trust.  Available  at:  https://ec.europa.eu/growth/content/safe-products-eu-single-market-commission-
acts-reinforce-trust-0_en 

18 

 
                                                      
 
Market  surveillance  is  supported  by  the  Safety  Gate/RAPEX  System  and  a  number  of  Joint 
Actions for specific products. 

Safety Gate/RAPEX aims to enable a quick exchange between 30 countries and the European 
Commission on measures taken against dangerous non-food products posing risks for the health 
and safety or the environment or any other aspect of public interest for protection of persons. It 
should  be  noted  that  the  data  submitted  to  Safety  Gate/RAPEX  depends  on  surveillance  and 
reporting practices as well as the frequency of those practices, which vary both between countries 
and  between  years  for  a  given  country.  Therefore,  Safety  Gate/RAPEX  data  is  neither 
comparable  across  Member  States,  nor  representative  of  the  actual  safety  level  in  the  EU. 
However,  the  data  is  used  below  to  identify  indications  on  equipment  which  tends  to  be  most 
involved in cases of dangerous products, as well as on their most recurrent origin. 

Safety  Gate/RAPEX  includes  more  than  28  000  alerts  overall42.  The  categories  used  by  Safety 
Gate/RAPEX differ from the product groups used in the market analysis presented in chapter 5. 

Following a filtering of the Safety Gate/RAPEX data based on a ‘risk of non-compliance with the 
LVD’, it appears that 3 223 alerts had been filed between 2005 and 2008. Among these products, 
76%  of  the  products  reported  originated from  China across the  years.  From  2009  onwards, the 
share of reported LVD products originating from China has remained in the range of 79% to 89% 
each year. As discussed in chapter 5.2 China is the EU’s largest trade partner of LVD products, 
which  partially  explains  the  prevalence  of  unsafe  Chinese  products  reported  in  Safety 
Gate/RAPEX. 

The most commonly reported risk types in Safety Gate/RAPEX for electrical appliances are the 
risk of electric shock (65% of all alerts in 2005-2017), the risk of fire (5%), and the combination 
of  the  two  (17%).  Other  types  of  risk  reported  include  choking,  cuts,  burns,  damage  to  sight, 
chemical, drowning, suffocation/asphyxiation, and unspecified injuries and health risks. 

The  most  commonly  reported  Safety  Gate/RAPEX  category  is  electrical  appliances  and 
equipment  (55%  of  alerts  over  2005-2018),  which  includes  equipment  such  as  small  kitchen 
appliances and home electronics, cables, chargers and adapters, and hand tools.  

However,  the  most  commonly  appearing  equipment  include  chargers  (including  ‘battery 
chargers’, ‘USB chargers’ and others), power supplies/power supply units, extension leads, and 
travel plug adaptors. The second most common category is lighting equipment (26% of the alerts 
in  2005-2018).  Among  the  most  common  types  of  equipment  in  this  category  are  ‘LED 
floodlights’, ‘table lamps’ and ‘LED lamps’. The third most common category is lighting chains43 
(13% in 2005-2018). 44 

Joint Actions Data are also relevant in regard to market surveillance activities. Among those, in 
recent years, a few were analysing electrical equipment falling under the LVD. 

42 Referenced on 26 May 2021. 

43 This category covers equipment simply labelled as ’lighting chain’ as well as ‘Christmas lighting chain’, 
‘LED lighting chain’, ‘lighting decoration’, ‘LED strip light’, ‘rope light’, ‘string lights’, twinkle net 
lights’, ‘LED tape’, ‘lighting tube’ and ‘flexible light tube’. 

44 Refer to Annex 4 

19 

 
                                                      
 
For example, in 2016, a Joint Market Surveillance Action (JA) on product safety of hairdryers, 
curling  irons  and  hair  straighteners45  was  carried  out. During  this  action, the results  showed an 
overall  percentage  of  non-conforming  products  at  58%.  While  the  majority  of  nonconformities 
concerned  poor  user  instructions,  there  were  some  significant  safety-critical  nonconformities, 
which is reflected in the 9 Safety Gate/RAPEX notifications, 18 withdrawn products and 13 sales 
bans. The failure  of  economic  operators to  provide  documents  of  conformity  upon  request  and 
the lack of traceability between the products shown in test reports and those products under test is 
concerning  and  suggests  the  need  to  maintain  or  even  increase  the  level  of  technical 
documentation reviews. 

Another  relevant  joint  action  was  carried  out  in  2015  for  toasters,  mixers  and  blenders46.  The 
results  surprisingly  highlighted  failure  rates  of  95%  for  blenders,  87%  for  mixers  and  58%  for 
toasters. The overall percentage of nonconforming products examined was 80%. Lack of safety 
information  and  warnings  in  user  instructions  accounted  for  the  largest  percentage  of  standard 
clause  failures.  Samples  demonstrating  non-conformity  with  multiple  standard  clauses  reached 
79%  for  blenders,  66%  for  mixers  and  20%  for  toasters.  Many  of  the  non-conformities  were 
across  several  safety-critical  clauses  such  as  protection  against  access  to  live  parts,  heating, 
abnormal operation, screws and connections and resistance to heat and fire. 

In 2011, the joint action on household appliances having child appealing designs47 was published. 
Data  on  163  different  household  appliances  (excluding  duplicates)  were  collected  and  113 
completed  questionnaires  were  received.  In  regard  to  this  data,  an  Atlas  was  developed  to 
establish  an  operational  and  practical  framework  to  assist  the  creation  of  a  common 
understanding amongst market surveillance authorities of the characteristics that may increase the 
child-appealing  nature  of  household  appliances  that  are  subjected  to  the  LVD  and  sold  on  the 
European market. 

In sum, market surveillance is an external factor affecting the full achievement of both the health 
and  safety  and  the  internal  market  objectives  of  the  LVD.  However,  in  light  of  the  upcoming 
legislative  changes,  the  situation  should  be  reassessed  in  the  near  future,  following  the 
implementation of all rules stemming from Regulation (EU) 2019/1020 on market surveillance. 

FINDINGS IN RELATION TO THE EFFICIENCY OF THE DIRECTIVE 

This section assesses the efficiency of the LVD, i.e. the extent to which the contribution to the 
objectives  as  discussed  in  the  previous  section  is  ‘good  value  for  money’  in  terms  of  the 
resources used to obtain the actual effects. 

The  analysis  of  costs-benefits  of  the  LVD  is  analysed  for  stakeholders:  national  authorities, 
economic operators and society as a whole. Different types of costs and benefits apply for each 
stakeholder group and they are briefly explained in this section. 

Costs for economic operators along the process of making low voltage products available on the 
internal market are as following: 

45 

https://www.prosafe.org/images/Documents/JA2016/Reports/FinalVersions/JA2016_HEA_Technical_
Report_Final.pdf 

46 https://www.prosafe.org/index.php/knowledgebase-2/category/toasters-mixers-blenders 

47 

https://www.prosafe.org/images/Documents/JA2009/ChApDes_Final_Report-version_20130304-

published.pdf   

20 

 
                                                      
Figure 14 – Mapping of costs borne by economic operators 

Source: Evaluation study 

The  first  type  of  costs  that  should  be  considered  are  those  related  to  any  specific  resources 
allocated to dealing with the compliance with the LVD. It appears from the interviews carried out 
that these costs are in fact non-significant. Indeed, regulatory compliance in general, appears to 
be  treated  within  a  quality  assurance-related  department,  which  therefore  covers  all  sorts  of 
legislation. In addition, companies irrespective of their size agree on the fact that LVD is to be 
considered effective and fairly easy to apply as it provides rather an overall framework of ‘good 
conduct’ than specific obligations. 

The analysis of compliance costs have been divided in two sub-categories, and pertain mainly to 
manufacturers duties. 

Specific resources costs, which are allocated to raise awareness of the LVD and to understand the 
requirements. None of the economic operators consulted reported specific resources allocated to 
the implementation of the LVD. This is an integrated part of the overall quality and regulatory 
compliance function of companies, which would exist irrespectively of the LVD. 

Technical  compliance  costs  are  required  for  manufacturing  of  products  in  line  with  the  LVD 
requirements. 

Harmonised standards are the preferred option for technical compliance for all types of economic 
operators, irrespective of their size, whenever they are available.  

Cost estimation for purchase standards are not easy. Anecdotic evidence from stakeholders shows 
that cost for purchase standards usually ranges between €400 and €1000 per product. It is to be 
noted that very often a single product involves multiple different standards (sometimes up to ten) 
that would bring the overall costs for standards up to €10 000 in average per product in a worst-
case scenario.  

The  costs  of  standards  are  in  indeed  significant,  and  even  more  so  for  smaller  players  (due  to 
their  limited  financial  availability).  In  addition  to  these,  some  operators  are  active  in  the 
standardisation  activities  by  attending  committee  meetings  and  participating  in  the  actual 
development of standards. 

All economic operators acknowledge the interests of standardisation but with a limited efficiency 
as they feel that the costs are high in proportion of the benefits.  

Some  evidence  from  the  manufacturers’  perspective,  shows  that  overall  costs  for  standards 
amount to less than 1% of annual turnover for the majority of respondents: 59 out of 75 for the 
implementation of new standards and 56 out of 89 for the design of new standards. 

Figure 15 – Manufacturers Q16: “Can you please estimate the overall annual average costs for 
activities linked to standardisation (% of annual turnover)?” 

21 

 
 
Source: Evaluation study, stakeholder survey 

It should also be noted that as regards the implementation of new standards, proportionally more 
manufacturers consider these costs as exceeding 5% of annual turnover than it being between 1% 
and 5%. On the contrary, for the design of standards, more manufacturers tend to think that costs 
range  between  1%  and  5%,  than  over  5%.  In  relative  terms,  the  cost  associated  with  the 
development  of  new  standards  i.e.  participation  to  technical  committees,  technical  drafts,  tests, 
etc., is perceived as higher than the actual use of standards. The findings are not sensitive to the 
size of the responding manufacturer. 

An  important  element  to  note  is  that  a  non-negligible  community  of  manufacturers  (45  out  of 
116) and mostly SMEs, rate these costs related to standardisation activities as ‘high’. 

Figure 16 – Manufacturers Q17: “Overall, how would you rate the cost for activities linked to 
standardisation indicated (in the previous question)?” 

Source: Evaluation study, stakeholder survey 

This indicates that even if these costs are lower than 1% or 5% of annual turnover, they are still 
considered to have a significant impact on businesses’ resources. Again,  while these trends are 
observed in the survey results for all manufacturers irrespective of their size, the impact could be 
expected to be relatively higher for a smaller player than a large corporation. 

22 

 
 
 
Lastly,  when  manufacturers  are  probed  about the  extent  to  which  the  aforementioned  costs  are 
proportionate to the benefits, the landscape is divided, as presented in the figure below: while 41 
out  of  116  respondents  assess  the  costs  as  proportionate  to  ‘some  extent’,  the  same  number  of 
manufacturers  (32  out  of  116),  consider  the  costs  as  proportionate  to  a  ‘great’  and  ‘limited’ 
extent.  The  additional  comments  received  largely  point  out  to  a  lengthy  publication  process  of 
harmonised standards at EU-level. 

Figure 17 – Manufacturers Q18: “To what extent do you consider the costs proportionate to the 
benefits for activities linked to standardisation?” 

Source: Evaluation study, stakeholder survey 

Procedural compliance costs which are related to the conformity assessment procedure, and the 
affixing  of  the  CE  marking.  The  manufacturer  has  to  apply  the  internal  production  control 
procedure (Module A), which, does not involve any third parties. It appears from the interviews 
carried out at national level that economic operators still involve third party laboratories  in the 
conformity assessment procedure in order to: 

-  Guide the process and ensure accuracy of results;  

-  Shift the responsibility to a recognised third party laboratory/certifier. 

Administrative  compliance  costs  such  as  monitoring  and  reporting  of  complaints  pertain  to  all 
types  of  economic  operators  including  manufacturers,  distributors and importers.  For  all  SMEs 
and  large  companies  perception  on  the  burden  associated  with  LVD  provisions  are  low  to 
medium  and  importers  and  distributors  participating  in  the  survey  provided  very  limited 
information about costs linked to the LVD provisions48.  

to  provide 

the  opinion  of 

list  of 
The  survey  asked  stakeholders 
administrative/procedural  compliance  provisions 
that  overall, 
manufacturers  consider  the  burden  arising  from  LVD’s  provisions  as  rather  low  (the  response 
was  selected  272  times  in  total  across  all  provisions  surveyed)  or  moderate  (the  response  was 
selected 266 times in total across all provisions surveyed). Based on the majority of responses for 
each  provision  surveyed,  the  burden  they  represent  can  be  summarised  as  presented  in  the 
following table. ‘Primary’ perception is represented by the answer having being selected the most 

the  LVD.  It  appears 

the  burden  of  a 

in 

48  Q:  “Please  provide  your  best  estimate  for  the  costs  borne  on  a  yearly  basis,  on  average,  by  your 

organisation for the following LVD provisions”, evaluation study 

23 

 
 
                                                      
by respondents, while ‘secondary’ perception is represented by the answer having being selected 
the second most times by respondents. 

Table 2 – Manufacturer’s perception on the burden associated with LVD provisions 

Source: Evaluation study 

to 

the  requirements  with  respect 

In terms of the specific requirements to prove compliance with the LVD, clarity does not seem a 
problem  to  most  economic  operators,  although  they  consider  some  provisions  of  the  LVD 
outdated.  This  applies  especially 
to  marking  and 
documentations.  There  have  been  technological  trends  that  could  be  applied  (e.g.  QR  codes, 
reference to websites), which with the current LVD provisions, is not possible yet. The related 
provisions are therefore considered as not responding to the current needs of economic operators 
that  could  be  changed  without  significantly  affecting  the  needs  of  other  stakeholders  (e.g. 
consumers).  Based  on  the  Public  Consultation  results,  consumers  would  also  favour  to  have 
information  (partially)  provided  in  electronic/digital  format.  Digital  documentation,  in  fact, 
generates  costs  reductions.  The  Public  Consultation  also  shows  that  while  the  level  of 
information  provided  by  the  manuals  was  generally  deemed  sufficient  by  the  majority  of 
respondents,  the  information  is  not  always  easy  to  understand  (e.g.  (part  of)  the  safety 
instructions)  or to  find (e.g.  contact  details  of  manufacturers  or importers).  All in  all, from  the 
economic operators’ perspective, it appears that costs related to the implementation of LVD can 
be ranked as follows (highest to lowest): 

1.  Technical compliance costs 
2.  Procedural compliance costs 
3.  Administrative costs 
4.  Specific resources costs. 

While some costs are perceived as being more justified/proportional to benefits than others, the 
overall  landscape  for  the  LVD  is  rather  positive  in  terms  of  costs  it  entails  for  economic 
operators, irrespective of their size. 

The  main  costs  for  national  authorities  are  associated  with  the  activity  for  the  market 
surveillance. Although it varies between EU Member States, it represents the highest ones. The 
main issues are lack of budget and adequate resources and the need for more resources. However, 

24 

 
 
a new Regulation on market surveillance and compliance49 will enter into force on the purpose of 
enhancing  and  modernising  market  surveillance  in  the  EU.  The  Regulation  will  apply  also  to 
LVD and might have a positive contribution to market surveillance. 

Economic operators are the principal beneficiary insofar; the LVD makes it easier to access 
the  internal  market.  Furthermore,  as  regarding  safety  related  elements,  economic  operators 
benefit  from  compliance savings  and  reputational  benefits.  Consumers (and  more  generally  tax 
payers) benefit from having safer products in the market.  

The  overall  opinion  of  economic  operators  concerning  the  efficiency  of  the  LVD  is  rather 
positive.  83%  of  manufacturers  (from  116  who  participated  in  analysis)  and  80%  of  importers 
and distributors (from 10 who participated in analysis) and all 40 business organisations reported 
that overall costs stemming from the LVD are absolutely to somewhat proportional to benefits). 

Figure  19  –  Manufacturers  Q23:  “Do  you  consider that  overall  costs  stemming  from  the  LVD 
are proportional to benefits?” 

Source: Evaluation study, stakeholder survey 

Figure 20 – Importers and distributors Q17: “Do you consider that overall costs stemming from 
the LVD are proportional to benefits?” 

Source: Evaluation study, stakeholder survey 

However,  3  respondents  out  of  116  deemed  the  costs  as  completely  disproportional,  and  16 
somewhat  disproportional.  Comments  received  included  notably  references  to  duplication  of 
work  due  to  overlapping  legislation  such  as  Directive  2014/53/EU  or  Directive  2014/30/EU.  It 
was also mentioned that “The burden is disproportionately higher for the "good" manufacturers 
and suppliers”. These opinions are aligned across SMEs and large companies.  

49    Regulation  (EU)  2019/1020  on  market  surveillance  and  compliance  of  products.  See:  https://eur-

lex.europa.eu/legal-content/EN/TXT/?qid=1562683986925&uri=CELEX:32019R1020 

25 

 
 
 
                                                      
Overall, the benefits generated by the LVD would significantly outweigh its costs when looked at 
from the aggregated level for all stakeholders. Relating to the relevance and added value of the 
Directive it can be concluded that the costs, which appear to be outweighed by benefits for all 
types of stakeholders involved, are borne for a justified cause.  

Regarding the potential for achieving some of the objectives of the LVD at a lower cost, it can be 
concluded  that  the  lack  of  quantitative  data  does  not  allow  to  conclude  on  this  question  with 
precision.  However,  the  positive  contribution  of  the  LVD  in  the  achievement  of  the  objectives 
could not be achieved at a lower cost, without compromising the safety objective, as the current 
conformity assessment procedure is already the less costly alternative. 

FINDINGS IN RELATION TO THE RELEVANCE OF THE DIRECTIVE 

This section presents to what extent the LVD still addresses current problems and needs. Given 
the length of the evaluation period, it is especially important to take into account developments in 
technologies, markets and the regulatory landscape. 

The main objectives of the LVD for safety and internal market are still relevant today, 45 years 
after  the  introduction  of  the  first  Low  Voltage  Directive.  The  LVD  is  relevant,  because  it 
addresses these objectives, and because there is no other legislation in place with the same scope. 

The LVD helps to reduce safety risks for consumers as only products that are safe and compliant 
are  put  on  the  market.  The  interviews  with  business  (associations)  as  well  as  the  workshops 
showed that for most economic operators (producers, traders), safety is considered a key issue for 
their competitiveness, as safety problems can damage their reputation, and therefore the LVD is 
seen to correspond to their needs. Some stakeholders have argued for a more precise list of safety 
risks, but others point to the risk that new, future, risks not being covered. 

Figure  21  –  Survey  question  on  relevance:  “How  relevant  do  you  consider  the  Directive  to 
ensure the safety of electrical products?” 

Source: Evaluation study, survey for the evaluation 

82% of the  221  respondents consider the  LVD  to  be  “very  relevant”  for ensuring  the safety  of 
electrical products. 

26 

 
 
With respect to the objective related to the free circulation, the LVD still responds to the needs of 
economic  operators  because  it  helps  to  prevent  diverging  regulations  between  EU  Member 
States,  thereby  preventing  trade  costs  and  creating  a  level-playing  field  in  the  EU.  The  level-
playing field that is created by the LVD is also beneficial for consumers, as the level  –playing 
field also helps to prevent unnecessary costs of trade in the internal market.  

Figure  22  –  Survey  question  on  relevance:  “How  relevant  do  you  consider  the  Directive  to 
ensure an internal market for LVD products?” 

Source: Evaluation study, survey for the evaluation 

74% of the respondents considered the Directive as ‘very relevant’ in achieving its objective of 
free circulation. 

The safety objectives should further be reflected in the future to examine whether there is need to 
address risks caused by the performance and not by the technical characteristics of the covered 
equipment. 

With  respect  to  conformity  assessment,  one  national  authority  expressed  the  opinion  that  the 
provisions of the LVD, referring to the conformity assessment, should be modified to only refer 
to  harmonised  standards.  Also,  the  provision  of  the  LVD  referring  to  national/international 
standards  was  considered  outdated,  as  “all  economic  operators  seek  the  presumption  of 
conformity”.  

Some stakeholders (notably national authorities like standardisation bodies or market surveillance 
authorities,  but  also  some  industry  representatives)  preferred  more  clarity  on  the  definition  of 
electrical  product  in  the  LVD.  With  the  current  definition,  it  is  not  clear  what  exactly  is 
considered the product; does it go down to component level, full product level or beyond systems 
that consist of different products? 

The scope as defined in the LVD has been largely unchanged since 1973. However, there have 
been important developments that have affected the scope of the Directive. First, the market for 
LVD has increased in size and varieties. In addition, at the same time, several other Directives 

27 

 
 
have been introduced since the first LVD came into force. These Directives cover products that 
could formerly be considered as within the scope of the LVD. This is especially true for products 
that now fall under the RED.  For example, computers without Wi-Fi connection are considered 
LVD  products,  whereas  when  they  have  Wi-Fi  connection, they  fall  under the RED.  And  with 
technological  developments,  it  will  be  the  case  for  an  increasing  number  of  different  products 
(e.g.  washing  machines  and  refrigerators  with  Wi-Fi).  There  are  other  Directives  which  have 
similar effects, as highlighted in the coherence section.  

The increasing overlapping between LVD and other Directives reduces the clarity of the scope of 
the LVD and, in some cases, increase the burden for economic operators. Although the issue was 
brought up by many stakeholders, we note that at the same time the incidence of these problems 
seems to be relatively low: for almost all products it is clear which Directive is applicable. (See 
section on coherence for details). 

However, some economic operators argued that it would be good to have a list of products that 
fall  under  the  LVD,  as  it  would  reduce  the  uncertainty  introduced  by  the  emergence  of  new 
Directives.  But  many  other  economic  operators  warned  that  making  an  explicit  list  of  LVD 
products  runs  the  risk  of  accidentally  excluding  products,  and  the  risk  that  with  new 
technological developments, the list would have to be continuously updated. 

The  voltage  limits  of  the  LVD,  especially  the  lower  voltage  limit,  have  been  a  point  of 
discussion with stakeholders and experts. Stakeholders have diverging views on this issue.  

It is mainly the businesses (the majority of manufacturers and business associations) who are of 
the opinion that the Directive should not cover the equipment operating at voltages below 50V 
AC / 75 V DC. These opinions are aligned across SMEs and large companies. Based on feedback 
received,  they  consider  most  of the products  below  the  voltage  limits  as safe,  also  because  the 
products still have to comply with the General Product Safety Directive 2001/95/EC (GPSD). In 
addition,  including  them  in  the  LVD  would  increase  the  burden  for  economic  operators. 
Especially where it involves very small, low cost products (e.g. birthday cards with music), the 
requirements of the LVD are considered too high in relation to their benefits. 

According to the opinion of technical experts, and as confirmed in stakeholder consultations, the 
fundamental problem is that the voltage limits that are used to categorise electrical equipment as 
LVD products, also suggest a categorisation of risks. This is not necessarily correct because not 
all risks have a firm relation to the product’s voltage50.  

Here below are summarised the main technical aspects: 

  The  safety  requirements  in  the  LVD  are  not  specified  and  go  beyond  electrical  safety. 
And the lower voltage limit unwarrantedly excludes electrical equipment that may also 
carry non-electrical safety risk. 

  The risk of thermal burn is a factor that may not depend on the voltage but instead could 
solely  depend  on  the  current  or  involved  chemical  processes  (e.g.  batteries).  Electrical 
equipment below the lower voltage limit could still contain the risk of thermal burns. 

  The debate  on  what  voltage  level  results  in  unacceptable risks  to  the  human  body  as  a 
result of electrocution is ongoing. This risk does not only depend on the voltage, but also 
on the maximum current an electrical source can deliver, the impedance of the medium 
and the time the electrocution takes place. There are several types of risks that can lead to 

50 For more details see section 5.3.2.2 https://ec.europa.eu/docsroom/documents/38701 

28 

 
                                                      
injury  or  death.  One  of  them  is  fibrillation  of  the  heart,  which  already  happens  at 
relatively low current (100 milli-Ampere). 

On  the  opposite  side,  the  majority  of  other  respondent  categories  with  a  view  on  this  (i.e. 
consumer organisations, EU Member State authorities but also distributors and importers as well 
as others) indicate that the lower voltage limit should be removed. Many stakeholders gave the 
example of products that are below the lower voltage limit of the LVD (most cited products are 
those  that  operate  on  lithium  batteries),  and  the  increasing  number  of  accidents  with  these 
products. While it is acknowledged that the extra-low voltage products, which are not covered by 
another specific Union legislation (such as RED) are covered by the GPSD, the LVD has more 
specific requirements and is therefore better able to ensure safety in their view.  

As regards the exclusions listed in Annex II to the LVD, many stakeholders do not have specific 
opinion or are of the opinion to not change the exclusions listed in Annex II. There is only one 
category of electrical equipment for which there are slightly more stakeholders encouraging their 
inclusion in the scope of the LVD, namely for “plugs and socket outlets for domestic use.”  

However,  based  on  the  stakeholder  survey,  the  definitions  of  the  equipment  and  phenomena 
excluded from the scope of the LVD could be clearer. The majority of the respondents had no 
opinion on the issue (e.g. due to a lack of expertise, given that it requires detailed knowledge of 
the Directive). Looking at the respondents who have an opinion on the definitions, we note that in 
general, less than half of the respondents indicate that the exceptions are well defined (“to a great 
extent”), while the majority indicates that this is not, to a limited, or to some extent, the case. 

Figure 23 – Stakeholder survey Q6: “To what extent are the definitions of products not included 
(in annex II) in the scope of the Directive well defined?” 

Source: Evaluation study, stakeholder survey 

29 

 
 
Furthermore, the majority of all respondent groups, including 9 out of 12 authorities, highlight a 
number of issues deriving from the fact that LVD safety objectives also apply to other product 
legislations (namely the RED and the MD). 

It needs to be reflected whether the LVD safety objectives need to apply to electricity meters as 
they are currently excluded from the LVD. The RED applies to those products only if they are 
radio  equipment.  Non-radio  electricity  meters  are,  however,  electrical  equipment  constructed, 
nowadays,  with  similar  materials  and  same  techniques  like  any  other  electrical  equipment 
covered by the LVD.  

Moreover, it shall also be reflected whether any new exclusions should be inserted in the Annex 
listing  the  exclusions,  in  order  to  exclude  products  whose  safety  is  specifically  covered  by 
another EU legislation such as the RED or the MD, even though the RED and the MD refer both 
to the safety objectives of the LVD. Other example would be the vehicle equipment covered by 
the EU legislation on type approval of vehicles51.  

Lastly, clarifications might be appropriate on the existing exclusions, if they concern equipment 
covered by more specific EU legislation (such as medical devices, marine equipment52, aviation 
equipment), so that those exclusions refer to any equipment to which that EU legislation applies.  
In addition, with such a reference, it will be clear that the LVD will not apply to equipment with 
non-medical  intended  purpose  referred  to  in  Annex  XVI  to  Regulation  (EU)  2017/74553,  when 
that Regulation will apply to that equipment.  

FINDINGS IN RELATION TO THE COHERENCE OF THE DIRECTIVE (LVD) 

This section presents the findings on the coherence of the LVD, in terms of internal coherence as 
well as external coherence.  

The internal coherence of the Directive analyses the extent to which the legal text is internally 
coherent, and clear to economic operators and other stakeholders involved in its implementation, 
and whether the scope is appropriate. The external coherence of the Directive analyses to what 
extent there are any issues of coherence with other legislations with similar objectives, if there 
are  overlaps  or  complementarities  between  the  Low  Voltage  Directive  and  any  other  EU 
legislations, and to what extent is the intervention coherent with wider EU policy. 

The majority of the stakeholders identified no significant problems with the internal coherence of 
the  LVD.  No  contradictions  have  been  identified  between  the  objectives  of  the  LVD  and  the 
wider  EU  single  internal  market  policy,  and  as  discussed  above,  stakeholders  credit  the 
Directive’s longevity and stability as one of the reasons why it is so successful. 

51 Such an exclusion will concern not only electric vehicle equipment which is more than 50 volts but also 
any  vehicle  equipment,  if  the  limit  of  50AC-75DC  is  removed  from  the  scope,  in  so  far  as  that 
equipment falls within the scope of the EU legislation on vehicles. 

52 Marine equipment within the scope of Directive 2014/90/EU on Marine Equipment is being certified by 
the  Member  States  in  accordance  with  the  relevant  international  maritime  safety  conventions. 
Equipment  to  be  placed  onboard  EU  ships  in  accordance  with  international  safety  standards  is 
therefore regulated exclusively by Directive 2014/90/EU, which should in any event be considered the 
lex specialis. 

53  Regulation  (EU)  2017/745  applies  to  equipment  with  non-medical  intended  purpose,  referred  to  in 
Annex XVI to that Regulation, when relevant Commission Implementing acts are adopted pursuant to 
that Regulation.   

30 

 
 
                                                      
Regarding  the  alignment  with  the  New  Legislative  Framework,  the  stakeholders’  attitude  is 
largely positive. The participants to the LVD Working Party Workshop54 considered that the new 
definitions  integrated  to  LVD  are  clear  and  helpful  –  other  aspects  were  not  mentioned  in  this 
context.  

One  of  the  four  EU-level  industry  representative  expressed  disappointment  that  the  alignment 
with the NLF had introduced uncertainty to the sector as well as some additional administrative 
costs  as  “even  slightly  updating  a  label  can  have  large  costs”.  However,  no  further  data  was 
discovered to support this.  

The  products  under  the scope  of  LVD  interact  with a  series  of  other  Directives  which  regulate 
aspects other than safety and might apply in conjunction with the LVD. For the great majority of 
the  stakeholders,  they  do  not  perceive  significant  incoherence.  However,  interactions  with  the 
RED, MD and GSPD Directives are perceived as creating significant challenges. 

Where the Directives have different responsible authorities, the change of scope means that the 
responsibility  to  test  the  product  suddenly  falls  on  an  authority  that  may  not  have  the  required 
specific training or testing equipment for the type of product in question.  

Some  of  the  Low  Voltage  Working  Party  Workshop  attendees  suggested  that  the  Directives 
should  be  geared  at  different  types  of  risks  rather  than  being  specific  to  certain  areas  of  the 
industry. Others suggested merging the Directives, however, there was no consensus on whether 
this would be a positive or negative change. Particularly the business representatives expressed 
concerns towards decreased clarity for economic operators. 

In addition, no significant incoherence was perceived with the Union legislation that regulates the 
safety of products which are listed in Annex II of the LVD (exclusions)55 but, as stated above, 
better clarity might be needed in Annex II. 

  Coherence with the Radio Equipment Directive 2014/53/EU (RED) 

The  RED  establishes  a  regulatory  framework  of  radio  equipment  (i.e.  equipment  which 
communicates  with  radio  waves).  When  RED  is  applicable,  the  LVD  and  EMCD  are  not 
applicable.  However,  RED  shall  ensure  the  protection  of  health  and  safety  of  persons  and  of 
domestic animals and the protection of property, including the objectives with respect to safety 
requirements set out in LVD, but with no voltage limit applying. 

The addition of radio functionalities to “traditional products” do push the products to go out of 
the scope of LVD and be subject only to RED.  

Opinions expressed in the LVD Working Party Workshop as well as standardisation authorities 
interviewed,  expressed  dissatisfaction  with  the  fact  that  introducing  Wi-Fi  connection 
automatically moves an appliance from the LVD scope to RED scope.  Potential safety risks of 
those  products  remain  largely  the  same,  relating  to  their  LVD  related  aspects  rather  than  IoT 
aspects.  It  was  suggested that the  designation could be  done  based on  their  main  function.  For 
example, in the case of a smart fridge the main function would be to cool (which imply to keep it 
under the LVD), rather than the use of radio communication (which would indicate moving to the 
scope of RED).  

54 Annex 2 
55  Such  as  Directive  2014/34/EU  on  equipment  and  protective  systems  intended  for  use  in  potentially 
explosive atmospheres (ATEX), Directive 93/42/EEC on Medical Devices  and Directive 2014/33/EU 
on Lifts. 

31 

 
                                                      
 
Correlating to the above, according to the respondents to the online survey56 the overlaps in scope 
between  the  LVD  and  other  legislation  (notably  RED)  is  a  problematic  issue  for  42.5%  of  the 
stakeholders (“great extent” or “some extent”). But for the 56% of the survey respondents this is 
not a problem at all, or just to a “limited extent”. The opinions of different stakeholder groups 
responding to the stakeholder survey are illustrated in the figure below. This problem was also 
observed during the LVD Working Party Workshop.  Clarity about the scope of the LVD has an 
impact on several aspects, and as underlined by national authorities, one of these consequences is 
the  variance  in  effectiveness  of  market  surveillance  activities  across  the  different  EU  Member 
States. 

Figure  24  –  Q3  all  respondents:  "A  number  of  products  falling  under  LVD  scope  also  fall  under  other 
legislations. To what extent do you consider this is a problem?" 

Source: Evaluation Study, stakeholder survey 

The opinions on a possible merge between the RED and the LVD are quite divided across type of 
stakeholders:    manufacturers  and  business  organisations  are  overwhelmingly  against  a  merged 
legislative act. Indeed, they consider the LVD as best practice example of a safety Directive and, 
on  the  contrary,  the  RED  was  described  very  negatively  due  to,  for  example,  additional  costs 
deriving  from  notified  bodies  (when  relevant)  or  provisions  of  additional  documents  such  as  a 
copy of the EU declaration of conformity or by a simplified EU declaration of conformity, and 
the obligation on packaging as mentioned above. On the other side, three consumer organisations 
and  six  national  authorities  see  the  merge  more  beneficial.  Among  cited  possible  benefits  of  a 
merged  Directive  are  a  greater  harmonisation  and  a  better  capability  of  taking  into  account 
technological developments: with the rise of Internet of Things, the connected products need to 
be safe both at software and hardware level. Several EU Member States participating in the LVD 
Working  Party  Workshop  also  noted  that  a  new  unified  Directive  would  potentially  lead  to 
additional administrative burden. 

56 Evaluation study  Annex G https://op.europa.eu/en/publication-detail/-/publication/48c2118c-4d4d-11ea-

aece-01aa75ed71a1/language-en 

32 

 
 
                                                      
Figure 25 – Q4 all respondents: "To what extent merging the scope of the LVD with the EMCD, the RED 
and the Terminal Equipment Competition Directive into one single act could facilitate implementation of 
these legislations?" 

Source: Evaluation Study, stakeholder survey 

While stakeholders gave credit to the latest LVD guidance document on how to cope with RED 
overlaps,  industry  and  national  representatives in  one  EU  Member  State  suggested  that  besides 
the  specific  Directive  guidelines,  overall  guidelines  on  the  interaction  of  different  Directives 
would be needed.  

  Coherence with the General Product Safety Directive 2001/95/EC (GPSD) 

The  GPSD57  applies  to  consumer  products  in  so  far  there  are  not  specific  provisions  with  the 
same  objective  in  the  EU  sectorial  legislation.  That  Directive  aims  to  ensure  that  only  safe 
consumer products are sold in the EU.  

GPSD  only  applies  in  the  absence  of  more  specific  provisions  in  the  LVD  and  in  Regulation 
765/2008/EC (which applies at the same time with, and as a complement to the LVD). 

Stakeholders discussed the interaction between the LVD and the GPSD in the context of products 
below  the  LVD  minimum  voltage  limit.  Issues  are  reported  to  arise  from  consumer  battery-
powered  products  that  are  below  the  LVD’s  lower  limit.  These  products  currently  fall  under 
GPSD. This, in turn, requires distribution of competences between authorities within a Member 
State which is an internal issue due to the fact that the EU legislation does not prevent the same 
authority to deal with products under both the LVD and the GSPD. 

  Coherence with the Machinery Directive 2006/42/EC (MD) 

The MD is a total harmonisation Directive, for the aspects and products it covers, based on the 
New  Approach  to  technical  harmonisation  and  standards.  It  covers  all  hazards  that  come  from 
machinery, including electrical hazards. However, according to the MD, the safety objectives set 
out in  LVD shall  apply  to machinery,  while obligations  concerning  conformity  assessment  and 

57 Directive 2001/95/EC of the European Parliament and of  the  Council of 3 December 2001 on general 

product safety (OJ L 11, 15.1.2002, p. 4). 

33 

 
 
                                                      
the  placing  on  the  market  and/or  putting  into  service  of  machinery  with  regard  to  electrical 
hazards are governed by the MD (Essential Health and Safety Requirement 1.5.1). 

The  MD  clarifies  the  borderline  between  its  scope  and  the  LVD  and  certain  categories  of 
electrical  and  electronic  machinery  products  are  hence  excluded  from  the  scope  of  the  MD, 
namely household appliances intended for domestic use; audio and video equipment; information 
technology  equipment;  ordinary  office  machinery;  low-voltage  switchgear;  and  control  gear; 
electric motors .  

The  first  category  “household  appliances”  designates  equipment 
typical 
housekeeping functions such as washing, cleaning, heating, cooling, cooking, etc. The appliances 
“intended for domestic use”, (i.e. for use by private persons in the home environment) fall under 
the  scope  of  LVD  and  not  under  MD;  on  the  contrary,  those  household  appliances  intended 
specifically for commercial or industrial use are included in the scope of the MD and so excluded 
from the LVD (but MD refers to the safety objectives of the LVD).  

intended  for 

The  interaction  with  MD  was  mentioned  by  some  stakeholders  at  the  LVD  Working  Party 
Workshop  as  a  coherence  issue.  The  fact  that  for  certain  product  categories  the  Machinery 
Directive does not provide a definition creates some (incidental) confusion as to when to take the 
end use as domestic or industrial (e.g. with laundry machines or 3D printers). This was seen as 
less of a problem with LVD, but rather with the MD, especially relating to the definitions or lack 
thereof of the latter. One national standardisation body also noted that the inclusion of a list of 
risks in the MD to solve the issue of determining which of the two Directives applies for which 
risk  does  not  fully  clarify  the  issue.  This  stakeholder  suggested  using  standards  and  guidance 
documents to solve the problem. 

The  Machinery  Directive  has  been  revised  and  the  Commission  adopted  on  21  April  2021  a 
proposal for a Regulation on machinery products58. Among other changes, the proposal reinforces 
the  coherence  with  the  LVD  by  considering  the  fact  that  electrical  and  electronic  products 
excluded from the Regulation will be also excluded from the Radio Equipment Directive when 
they  incorporate  wi-fi.  The  proposal  is  subject  to  ordinary  legislative  procedure,  to  be  adopted 
jointly by the European Parliament and the Council of the EU. 

  Coherence with the WEEE Directive 2012/19/EU and the RoHS Directive 2011/65/EU 

The  WEEE  Directive  2012/19/EU59  (waste  electrical  and  electronic  equipment)  aims  to 
contribute to sustainable production and consumption by preventing the creation of WEEE as a 
first  priority,  contributing  to  the  efficient  use  of  resources  and  the  retrieval  of  secondary  raw 
materials  through  re-use,  recycling  and  other  forms  of  recovery,  and  improving  the 
environmental  performance  of  everyone  involved  in  the  life  cycle  of  electrical  and  electronic 
equipment (EEE) 

The  RoHS  Directive  2011/65/EU60  (restriction  of  the  use  of  certain  hazardous  substance  in 
electrical  and  electronic  equipment)  aims  to  prevent  the  risks  posed  to  human  health  and  the 
environment  related  to  the  management  of  electrical  and  electronic  waste.  It  achieves  it  by 
restricting  the  use  of  certain  hazardous  substances  in  EEE  that  can  be  substituted  by  safer 
alternatives.  These  restricted  substances  include  heavy  metals,  flame  retardants  or  plasticizers. 

58 EUR-Lex - 52021PC0202 - EN - EUR-Lex (europa.eu) 

59 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02012L0019-20180704 

60 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0065 

34 

 
                                                      
The Directive promotes the recyclability of EEE, as EEE and its components that have become 
waste contain fewer hazardous substances. At the same time, it ensures a level playing field for 
manufacturers and importers of EEE in the European market. 

In January 2017, the Commission adopted legislative proposals to introduce further adjustments 
in the scope of the RoHS and the WEEE Directives. 

The vast majority of products that fall within the scope of the LVD also fall within the scope of 
RoHS and WEEE Directives. 

Since  2019  any  product  which  meets  the  EEE  definition  falls  under  the  scope  of  the  RoHS 
Directive.  However, several product groups are excluded from the scope. It is the responsibility 
of the manufacturer, importer, or any other economic operator involved to assess whether his tool 
or installation benefits from an exclusion. Where a combination of equipment, components and 
sub-assemblies is being brought together or combined and placed on the market as a single piece 
of equipment or a manufacturing process line, then consideration could be given to application of 
other directives such as the EMCD, LVD and MD. Due to the nature of the definitions, assigning 
broad  types  or  classes  of  equipment  to  products’  category  is  not  possible.  Decisions  are  to  be 
taken on a case-by-case basis considering all criteria in each definition.  

Even  though  no  significant  issues  relating  to  the  interaction  with  the  RoHS  and  WEEE  
Directives has been explicitly reported, it appears that the definition of ‘electrical and electronic 
equipment’  offered  by  some  of  the  other  Directives  (such  as  RoHS)  is  sometimes  used  as 
substitute for interpreting the LVD, which offers no such definition. 

FINDINGS IN RELATION TO THE EU ADDED VALUE OF THE LVD 

The  LVD  aims  to  eliminate  barriers  and  ensure  free  movement  of  (compliant)  products  on  the 
single  internal  market,  as well  as  to  ensure  safety  of  those  products.  As  such, its  purpose is  to 
avoid  fragmentation  of  safety  standards  and  to  realise  the  internal  market  for  products  in  its 
scope.  The  majority  of  all  stakeholder  categories61  consulted  also  consider  that  the  LVD  has 
improved the safety of electrical products in the EU to a significant extent. 

The  majority  of  stakeholders  view  positively  the  role  of  the  LVD  in  facilitating  the  free 
circulation of compliant products within the internal market 

LVD ensures the safety of products and eases the launch of products, particularly compared to 
the situation where each Member State would have its own system in place. And the stakeholders 
consider that LVD provisions imply a low to medium burden.  

Regarding  the  objective  of  ensuring  safety  of  electrical  products  in  the  internal  market,  the 
majority  of  all  stakeholder  groups  consider  that  the  LVD  is  “very  relevant”  for  ensuring  the 
safety of electrical products. Standards are widely reported as the most widely used and also the 
most  preferred  method  for  ensuring  the  compliance  of  electrical  equipment.  According  to  the 
stakeholders, the standards ensure the convergence of state-of-the-art practices across the EU, as 
well as the safety of products by formalising the essential safety requirements. 

The stakeholders also credit the fact that LVD also facilitates cooperation through the AdCo and 
the Working Party, allowing for discussion and change of views between national authorities and 
economic operators, creating synergies, facilitating the exchange of best practices and sharing of 
experiences,  allowing  for  refining  and  clarifying  the  common  rules  and  practices.  Such 

61  Sections 

  0  and  https://op.europa.eu/en/publication-detail/-/publication/48c2118c-4d4d-11ea-aece-

01aa75ed71a1/language-en  

35 

 
                                                      
communication platforms with similar level of authority and geographical reach would be more 
difficult to create outside the framework of an EU level legislation. 

Without  EU-level  action,  it  is  possible  that  safety  standards  and/or  procedures  for  addressing 
dangerous products could differ between EU Member States, although the extent of diversity of 
approaches is challenging to establish. In any case, this could hinder the cross-border market of 
products,  and  information  on  dangerous  equipment  spread  in  different  countries  would  not 
automatically be shared as widely and comprehensively. In addition, consumers could not rely on 
uniform safety standards across the EU. As discussed in section “Analysis of the LVD market”, 
the intra-EU market is growing in volume, highlighting the importance of common regulation. 

36 

 
 
 
 
 
8  CONCLUSIONS 

There  is  a  consensus  among  all  stakeholders  that  overall  the  Directive  has  successfully 
contributed  towards  its  objectives  by  facilitating  the  free  movement  of  electrical  equipment 
across  the  Union  and  protecting  consumers'  and  users'  health  and  safety.  Regarding  its  general 
objectives  related  to  internal  market  and  health  and  safety,  the  LVD  can  be  considered  fairly 
effective.  Factors  hindering  the  full  achievement  of  its  objectives  are  mostly  external  to  the 
Directive. 

Concerning the Directive’s effectiveness for the internal market, the LVD is generally seen as 
contributing  to  an  effectively  operating  internal  market  for  electrical  equipment  in  its  scope.  It 
removes  regulatory  and  procedural  barriers  to  trade,  thereby  facilitating  intra-EU  trade  among 
economic  operators  by  establishing  a  set  of  harmonised  rules  and  procedures  for  electrical 
equipment throughout the EU. To that end, harmonised standards are confirmed to be an effective 
means  to  ensure  Directive’s  adaptability  to  market  trends,  including  technological  innovations. 
No major cases of discrepancies have been detected across EU Member States in interpreting the 
requirements of the LVD for particular products.  

Market surveillance and conformity assessment procedures are seen as areas for improvement in 
ensuring  the  Directive’s  effectiveness  in  the  future.  Market  surveillance  is  not  considered 
effective  in  implementing  and  enforcing  the  LVD.  The  development  of  e-commerce  adds 
additional challenges to LVD enforcement as it leaves room for uncompliant products not being 
intercepted,  therefore,  affecting  the  level  playing  field  on  the  internal  market..  Market 
surveillance  is  outside  the  remit  of  the  LVD.  However,  with  the  implementation  of  the 
Regulation (EU) 2019/1020 on market surveillance, which enters into force on 16 July 2021, the 
issues  related  to  enforcement,  identified  by  the  evaluation,  will  be  tackled.  Regarding  the 
procedures for conformity assessment, the absence of the possibility of using third party may be 
seen  as  not  helping  the  SMEs.  In  general  the  SMEs  seek  support  and  guidance  for  conformity 
assessment due to lack of means e.g. laboratories/expertise or for competitiveness reasons. 

Regarding the Directive’s effectiveness for health and safety, the opinions of stakeholders are 
rather  positive  regarding  the  contribution  of  the  LVD  to  the  safety  of  products.  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 
majority  of  manufacturers,  consumers  associations  and  business  associations.  This  opinion is  a 
bit more nuanced among importers, retailers and national authorities (around half of them). Some 
stakeholders,  such  as  consumer  organisations,  expressed  concern  on  the  extent  to  which  the 
current  conformity  procedures are  effective  enough  for  riskier  products,  wondering  whether  all 
products should have the same procedure, or whether a distinction between risk-levels would be 
more appropriate to prevent accidents (current self-certification for low-risk products and third-
party  certification  for  products  with  higher  risks).  However,  the  LVD  currently  does  not  make 
such distinction. Harmonised standards are seen as the best method to ensure safety compliance 
of  the  electrical  equipment  given  that  the  essential  safety  requirements  of  the  Directive  are 
considered  generic  and  succinct  by  stakeholders.  Finally,  as  stated  above,  issues  with  market 
surveillance also impact health and safety objectives.  

Concerning the efficiency of the Directive, the benefits generated by the LVD outweigh its costs 
for each type of stakeholders – including national authorities, economic operators (irrespective of 
their size of place in the value chain) and consumers, both individually and as a whole.  

According to both economic operators and consumers, the requirements related to marking and 
documentation are  affecting  the  efficiency  of  the  Directive  given  that they  do  not  facilitate the 
use of internet-related solutions in combination with information on the product/in manuals.  

37 

 
The costs related to standards are estimated between 1 and 5 % of the annual turnover. Economic 
operators acknowledge the importance of standardisation and they feel that the costs are high in 
proportion of the benefits. However, this factor is outside the scope of the LVD. 

The  remaining  of  the  costs  (procedural  compliance  costs,  administrative  costs  and  specific 
resource costs) for economic operators are viewed as less problematic.  

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

The LVD reduces safety risks for consumers as only products that are safe and compliant are put 
on the market. For most economic operators (producers, traders), safety is considered a key issue 
for their competitiveness, as safety problems can damage their reputation, and therefore the LVD 
is seen to correspond to their needs. 

With respect to the objective related to the free circulation, the LVD still responds to economic 
operators'  needs  because  it  helps  to  prevent  diverging  regulations  between  EU  Member  States, 
thereby preventing trade costs and creating a level-playing field in the EU. It addresses both the 
needs  of  consumers  (which  expect  safety  and  benefit  from  a  free  circulation  on  the  internal 
market) as well as those of economic operators (most of whom consider safety as a key aspect of 
their competitiveness, and have the need for reducing barriers for intra-EU trade). 

The  introduction  of  other  Directives,  notably  the  Radio  Equipment  Directive,  together  with 
technological changes such as the increased use of connected products and the Internet of Things, 
has  reduced  the  scope  of  the  LVD  in  terms  of  number  of  products  covered.  Nevertheless,  the 
provisions  of  the  LVD  related  to  safety  are  formulated  in  a  technological-neutral  way  and  can 
therefore be applied also to new products.  

Regarding  the  removal  of  the  lower  voltage  limits  of  50V  for  alternating  current  and  75 V  for 
direct  current,  the  evaluation  indicates  divergent  views  between  the  various  stakeholders 
consulted with no clear indication if such change would be beneficial.  

Regarding  the  coherence  with  other  legislative  acts,  the  alignment  to  the  New  Legislative 
Framework  ensures  to  a  certain  extent  the  Directive’s  coherence  with  the  rest  of  the  internal 
market legislation for products. However, the interplay 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 stem from problems 
with the other Directives, respectively the Radio Equipment and the Machinery Directives. The 
revision  of  the  Machinery  Directive  has  considered  the  coherence  problems  emerged  by  the 
interplay  between  the  two  Directives,  by  bringing  legal  clarity  to  the  specific  list  of  LVD 
products excluded from the application of the Machinery Directive. 

The  LVD  brings  added  EU  added  value,  providing  a  common  set  of  rules  and  standards, 
facilitating the free circulation of compliant products within the internal market and preventing 
fragmentation  of  safety  rules  across  the  EU  Member  States.  The  industry  benefits  of  a  level 
playing field through clear rules for compliance and consumers by guaranteeing 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. It has stood the test of time. However, specific improvements, to ensure Directive's 
effectiveness going forward, have been identified by this evaluation. 

On one hand, issues were identified that directly result from the Directive itself.  

38 

 
 
The  first  one  is  the  absence  of  third  party  inspection  body  in  the  process  of  conformity 
assessment. The  present analysis  could not infirm  that  the current  procedure is not  effective  in 
providing for the safety of products in all cases. This absence is seen as not helping SMEs who, 
in  general,  seek  support  and  guidance  for  conformity  assessment  because  they  may  be  less 
accustomed  to  such  duties  and  may  lack  of  internal  competencies.  However,  the  majority  of 
stakeholders  views  are  positive  towards  the  current  conformity  procedure  arguing  that  such 
change would not address the safety of products. Further research, as indicated by some Member 
States,  is  required  to  determine  if  the  inclusion  of  another  conformity  assessment  module 
(Module  B)  would  provide  benefit  to  the  Directive,  notably  (1)  through  the  mandatory 
conformity  assessment  by  third  parties  for  certain  high  risk  products,  (2)  through  the  optional 
conformity  assessment  by  third  parties  for  certain  products.  The  LVD  does  not  make  such 
differentiation between products.  

The  second  one  is  the  requirements  relating  to  marking  and  documentation,  which  do  not 
facilitate the use of internet related solutions in combination with information on the products/in 
manuals. Based on the response from the surveys, there is room for improvement regarding the 
information provided to consumers with LVD products. Consumers are currently not always able 
to easily find and understand the information provided. However, this is an issue identified across 
other sectors of new approach legislation and that, for coherence purposes, could be assessed and 
addressed by a possible future reform of the New Legislative Framework. 

The  third  one  is  linked  to  the  coherence  with  other  directives.  While  there  may  be  a  need  for 
better  coherence  with  other  legislations  that  the  Directive  interplays  with,  particularly  with  the 
Radio  Equipment  Directive,  the  evaluation  does  not  indicate  that  a  merger  between  the  two 
legislations would be beneficial. Minor issues were also identified with the Machinery Directive, 
GPSD and WEEE as regard to the scope definition, which may lead to similar competency gaps 
as  the  RED  connection.  However,  most  stakeholders  considered  that  these  issues  stem  from 
problems with the other Directives and not from the LVD. 

On the other hand, the other issues identified, fall outside the remit of the LVD. 

The  first  one  is  the  effectiveness  of  market  surveillance  activities.  They  are  seen  as  currently 
uneven throughout the EU. The extent to which Member States are able to identify uncompliant 
products is dependent on their authorities’ resources, which vary across the EU. While this is an 
element beyond the remit of the LVD, it negatively affects the enforcement of the Directive in 
terms  of  its  health  and  safety  provisions.  Furthermore,  due  to  the  introduction  of  Wi-Fi 
connection in equipment, competency gaps for the testing and market surveillance authorities can 
appear.  

The second one is related to enforcement of the developing e-commerce. This issue comes from: 
an increased number of non-EU economic operators active in the EU and the difficulty of tracing 
them, a lack of physical access to the products on the side of national market authorities making 
it difficult to sample products or conduct risk assessments, and a lack of awareness on the side of 
consumers about product compliance online. Some steps are taken for an increased clarity of e-
commerce rules62 but challenges remain in particular related to market surveillance.  

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

published: 

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

39 

 
                                                      
 
These two aspects should however be examined in light of the Goods Package 2017 and after the 
entry into application of the Regulation (EU) 2019/1020 that should address both concerns. 

40 

 
 
 
 
 
 
                                                                                                                                                              
 
9  ANNEXES 

ANNEX 1 

PROCEDURAL INFORMATION 

1. Lead DG, Decide Planning/CWP references  

Lead  DG:  Directorate-General  for  Growth  -  Internal  Market,  Industry,  Entrepreneurship  and 
SMEs (DG GROW); Unit C3: Engineering, Maritime and Rail Industries.  

Agenda planning/work programme reference: 2015/GROW/051  

2. Organisation and timing  

Organisation and timing: the inter-service Steering Group consisted of SG, DG JUST, DG EMPL 
and DG CNECT. After the kick-off meeting on 5 February 2016, it met two times in 2016, two 
times in 2017 and once in 2018.  

3. Exceptions to the better regulation guidelines  

Not applicable.  

4. Consultation of the RSB (if applicable)  

Not applicable.  

5. Evidence, sources and quality  

The  evaluation  study  “Interim  evaluation  of  the  Low  Voltage  Directive  2014/35/EU  Final 
Report”63  was outsourced to a consultant and was one of the main sources of information for this 
Evaluation of LVD 2014/35/EU. Study identify to obtain a better understanding of the market, to 
monitor the implementation of the LVD in EU Member States, and to assess the  effectiveness, 
efficiency, coherence, relevance, and EU added-value. Each phase contains several tasks which 
take  into account  the  data collection  tools, timetables  and  deliverables. These tasks  are  aligned 
with the objectives of the study and with the requirements of the Better Regulations Guidelines64 
for evaluations.  

63 https://ec.europa.eu/docsroom/documents/38701  

64 https://ec.europa.eu/info/better-regulation-guidelines-and-toolbox_en  

41 

 
 
 
 
 
 
                                                      
 
SYNOPSIS REPORT OF STAKEHOLDER CONSULTATIONS 

ANNEX 2  

The present synopsis resumes the main inputs received from all consulted stakeholders during the 
evaluation.  

The Stakeholder survey’s objective was to gather information on understanding, implementation 
and enforcement of the LVD from businesses, business and consumer associations, 
standardisation bodies, national authorities and consumers. 

The Public Consultation was aimed at gathering factual information, data, knowledge and 
perception by final consumers and citizens across the EU about relevance of the scope and the 
objectives of the LVD compared to the needs of the consumers; and also about effectiveness of 
the Directive in ensuring consumers’ safety.  

The validation Low Voltage Working Party Workshop had the purpose to discuss the preliminary 
findings extracted from the survey and the public consultation with the LVD Working Party prior 
to their validation. 

2.1 Stakeholder survey analysis 

2.1.1 Effectiveness 

Implementation and application of the Directive 

73% of the surveyed manufacturers experienced minor or no difficulties at all when applying the 
LVD. In addition, only 5% of the manufacturers reported difficulties to a great extent: these were 
6  out  of  the  116  taking  part  in  the  manufacturers’  survey.  7  medium  manufacturers  reported 
difficulties to “some extent”, for 18 out of 26 SMEs (69%) there are no particular difficulties (or 
just to a “limited extent”, if any).  78% of manufacturers reported that the LVD facilitates these 
exchanges  to  at  least  some  extent  (the  majority  was  satisfied  to  a  great  extent).  Only  four 
manufacturers considered that the LVD does not facilitate EU trade in any way. These opinions 
are aligned across SMEs and large companies. 78% of the manufacturers reported no issue with 
the implementation of the LVD in different Member States. According to distributors and 
importers participating in the survey, there were no significant issues reported in the flows of 
goods within the single internal market, with 8 out of 10 reporting “minor” or no problems at 
all. 2 consumer organisations reported that intra-EU exchange was facilitated to a “great extent”, 
the  other  two to  “some  extent”;  3  consumer  organisations  out  reported  safety  improvements  to 
“some extent”. Market surveillance authorities described several difficulties when applying the 
LVD in their countries. The two main observations were the lack of resources by the authorities 
and  lack  of  knowledge  by  certain  categories  of  economic  operators.  A  greater  cooperation 
between market surveillance authorities was encouraged to ensure safety especially that the LVD 
makes  manufacturers  fully  responsible  for  compliance,  removing  any  responsibility  from 
distributors and importers. 

Health and safety 

The perception about the safety of electrical products is in general quite positive (with the 
exception  of  the  issue  related  to  voltage  lower  than  50V).  Only  a  minor  part  of  manufacturers 
(12%) reported “limited” or” not at all” guarantee of safety. The majority of complaints in this 
area  were  related  to  the  enforcement  of  the  LVD,  especially  for  what  concerns  the  products 
manufactured outside the EU.  18 out of 26 (69%) SMEs reported an improvement in the safety 

42 

 
 
of electrical products thanks to LVD, to a “great” or at least to “some” extent. The figure is even 
higher  for  large  companies  (85%),  but  the  overall  trend  is  confirmed  and  not  significantly 
affected  by  the  size  of  the  company.  Over  60%  of  business  associations  and  consumer 
organisations  are  also  satisfied  to  a  great  extent  with  the  guarantee  of  safety  due  to  the  LVD 
provisions .10 cable manufacturers’ associations reported LVD limited success in improving 
health  and  safety  of  electrical  products  sold  in  the  EU  market  advocating  for  a  better 
compliance to product standards.  Manufacturers as well as importers and distributors agree 
on the high guarantee of safety ensured by the LVD provisions. Only one importer reported that 
the LVD contributes to safety only to a limited extent. Market surveillance authorities largely 
agree with manufacturers as well as importers and distributors. 8 out of 11 market surveillance 
authorities consider the provision safety-enabling to some or to a great extent. The only remarks 
made  by  some  authorities  are  related  to  possible  changes  in  the  documentation  required  to 
accompany the products (e.g. compulsory DoC as requested for Directive 2014/53/EU) or to the 
opportunity  to  perform  risk-based  approach  conformity  assessments.  For  75%  of  business  and 
consumer  organisations  participating  in  the  survey,  the  conformity  assessment  procedures 
provided  by  the  LVD  ensure  safety  of  electrical  products  to  a  great  extent.  According  to  the 
respondents  to  the  survey,  electric  lighting  equipment,  consumer  electronics  and  electric 
domestic  appliances  are  the  main  categories  found  to  be  non-compliant  within  the  EU. 
Regarding the number of fatalities registered, there is a lack of data.65 Only one public authority 
reported more than 5 fatalities linked to the LVD products. 

Effects of the absence of notified bodies 

According to the manufacturers, there is no strong correlation between the absence of notified 
bodies from the conformity assessment procedure required by the LVD and the suggested impact 
on internal EU exchange, safety of products and costs to industry. For other manufacturers this 
had  at  least  a  positive  effect  on  reducing  costs  for  the  various  industries.  For  certain  SMEs,  it 
might be difficult to have the required technical expertise to demonstrate compliance, especially 
when  developing  innovative  products  which  require  a  mix  of  different  technical  requirements.  
However, only 8 SME manufacturers out of 26 reported a “somewhat negative impact” and only 
1  SME  a  “strong  negative  impact”  on  safety  of  products. There  is  a  general  acknowledgement 
that “Notified bodies are helpful in some special cases and safety aspects. Nevertheless, as long 
as 100% of the responsibility for product liability falls with the manufacturer, the NBs are only 
consultative  institutions  and  cannot  take  away  the  manufacturer's  duties”.  Importers  and 
distributors’ views about the absence of notified bodies show some differences compared to the 
feedback gathered from manufacturers, even though there is not much information and consensus 
on the real impact of the provision (and how much it is strictly perceived as a “collateral effect” 
of the LVD), importers and distributors seem to be more worried about the impact that the 
absence of notified bodies might have had on the safety of products than the manufacturers, 
with 5 respondents reported a “somewhat negative impact”. On the other hand, this provision is 
seen as a possibility for the industry to reduce costs. The authorities’ views about the absence of 
notified  bodies  shows  again  some  concerns  in  terms  of  the  impact  of  this  provision  on  the 
safety  of  products.  The  authorities  have  the  most  negative  view  of  all  stakeholder  categories: 
none of them reported “somewhat positive” or “positive impact” related to the absence of notified 
bodies, whereas eight out of twelve consider the provision having at least a somewhat negative 
impact.  Some  concerns  about  safety  of  products  were  raised  also  by  business  associations  and 
consumer organisations when asked about the absence of notified bodies.  

65 For example, the UK was unable to provide disaggregated data for fatalities and incidents.  

43 

 
 
                                                      
Standardisation 

27%  of  manufacturers  mentioned  achieving  safety  benefits  due  to  standardisation  of  the 
LVD as the main benefit. The other 73% of respondents indicated other aspects as main benefits, 
such  as  a  level  playing  field,  an  improved  internal  market  for  products  or  did  not  provide  an 
answer. Some manufacturers commented that the benefits deriving from standardisation consist 
in “Defining clear & detailed rules for certain product categories to enable a level playground in 
the common market” and also that “A simple directive and well-designed standards, drafted by 
experts, creates safe products and a level playing field”. These opinions are aligned across SMEs 
and large companies. 

2.1.2 Efficiency 

9 out of 10 distributors and importers considered an improvement in intra-EU exchange due to 
the  LVD.  8  out  of  10  respondents  reported  health  and  safety  protection  as  a  moderate  or  high 
benefit:  although  they  somewhat  expressed  concerns  about  safety  without  notified  bodies,  the 
level of safety ensured by the LVD it is still seen as satisfying. When assessing LVD benefits, 
authorities’ views are consistent with manufacturers, distributors and importers. This underlines 
positive results with easier intra-EU exchange and health and safety protection: 9 authorities out 
of 12 reported “high” benefits. In terms of overall benefits stemming from the LVD provisions, 
there is an overall consensus among business organisations that these benefits are high: easier 
intra-EU  exchange  and  health  and  safety  protection,  with  63%  of  respondents  being  highly 
satisfied. This question was not presented to consumer associations. 

Costs of standardisation 

There  are  some  issues  regarding  data  availability  on  costs  related  for  standardisation.  In 
this  case,  it  is  mainly  related  to  the  interaction  between  manufacturers  and  other  stakeholders 
(such  as  standardisation  bodies,  industry  associations,  etc.)  which are  responsible  for  recording 
these costs. However, given the results available and the evidence collected in other questions of 
this survey, we can assume that the annual costs due to standardisation related activities are very 
low. 79% of the surveyed manufacturers stated that these costs amount to less than 1% of their 
turnover.  10  manufacturers  (13%)  reported  annual  costs  for  standardisation  above  5%  of  their 
annual turnover, but 45 manufacturers (39%) reported  high costs for standardisation, which may 
indicate that for these manufacturers costs are high costs even if lower than 5% of the turnover. 
These opinions are aligned across SMEs and large companies. There are discrepancies between 
data provided by the stakeholders, notably between reported costs of standardisation and a 
ratio between costs and benefits. In fact, 39% of manufacturers reported high costs for activities 
linked for standardisation. However, for 63% of them these costs are proportionate to the benefits 
(at  least  to  some  extent).  The  participation  in  consultation  bodies  and/or  standardisation 
committees  of  the  LVD  is  not  very  high:  only  6  business  associations  and  consumer 
organisations reported their participation to both committees, whereas 25 business organisations 
only participated to the standardisation committees. From the consumer organisations side, 3 out 
of  4  did  not  participate  in  the  consultation  bodies,  whereas  3  out  of  4  declared  that  they  have 
participated in the standardisation committees of the LVD. About the main benefits coming from 
participation  in  standardisation  committees  and  consultation  bodies,  the  respondents  ranked 
high the opportunity to play an active role in setting standards.  

Costs of LVD provisions 

Overall,  the  responding  manufacturers  did  not  report  high  cost  burden  related  to  LVD 
provisions.  The  LVD  provisions  are  largely  reported  to  be  not  burdensome  at  all  for 
“monitoring  complaints  and  keeping  incident  records”  and  especially  “affixing  of  the  CE 

44 

 
 
marking  and  labelling  the  product  appropriately”.  However,  more  than  50%  (64  out  of  116) 
manufacturers  reported  “medium  burden”  for  “drawing  up  safety  instructions  and  safety 
information including translations”. The burden was also reported as “moderate” by circa 40% 
of  the  respondents  for  “production  and  archiving  of  technical  documentation  and  of  EU 
declaration of conformity”, “conducting sample tests” and “carrying out conformity assessment 
following module A”. These opinions are aligned across SMEs and large companies. 

Importers and distributors participating in the survey provided very limited information about 
costs  linked  to  the  LVD  provisions.  16%  of  manufacturers  reported  that  the  overall  costs 
stemming  from  the  LVD  are  not  that  proportional  or  not  proportional  at  all.  No  business 
organisation  reported  higher  costs  compared  to  the  benefits  resulting  from  LVD  provisions. 
Consumer organisations answered in the same way. 

2.1.3 Relevance 

Relevance regarding the safety objective 

As  there  is  a  broad  consensus  among  respondents  (82%)  about  the  relevance  of  LVD  for 
ensuring  safety  requirements  for  electrical  products.  Only  a  very  small  part  of  the 
stakeholders (13 out of 221) considered the LVD “Very irrelevant” in achieving this objective. 
The  opinions  are  aligned  across  SMEs  and  large  companies.  92%  of  the  respondents  in  the 
“others”  category  (34  out  of  37)  stated  that  LVD  is  “Very  relevant”  or  at  least  “Somewhat 
relevant” in ensuring the safety of electrical products. 

Relevance regarding internal market objective 

A  positive  feedback  was  received  about  the  LVD  capability  to  ensure  a  well-functioning 
internal  market:  74%  of  the  respondents  considered  LVD  “very  relevant”  in  achieving  this 
objective,  compared  to  just  the  6%  stating  the  opposite  (“very  irrelevant”).  Given  the  overall 
consensus,  this  statement  is  confirmed  especially  by  manufacturers,  importers  and  distributors: 
when  requested  to  list  the  main  “pros”  about  LVD,  “improved  access  to  all  EU  markets”  was 
often acknowledged by these types of stakeholders. The opinions are aligned also across SMEs 
and large companies. In terms of capability of the LVD to ensure an internal market for products 
falling  within  its  scope,  there  is  very  strong  consensus  within  the  “others”  group:  92%  of  the 
respondents (34 out of 37) stated that LVD is “Very relevant” or at least “Somewhat relevant” in 
ensuring an internal market for electrical products. 

Scope 

67% of the respondents considered that the scope of the Directive in terms of voltage rating 
is still appropriate to a “great” or to “some” extent. These opinions are aligned across SMEs 
and  large  companies.  However,  26%  of  the  surveyed  stakeholders  stated  that  “it  is  not 
appropriate anymore” or appropriate only to a “limited extent”, suggesting that the lower limits 
of  the  Directive  should  be  removed  or  lowered  even  more.  The  main  concerns  were  about 
products  below  50V  that  might  be  considered  dangerous,  such  as  lithium  batteries  (also 
rechargeable ones) and battery-powered devices that might be affected by fires due to faults in 
circuitry.  59%  of  the  respondents  belonging  to  this  category  reported  that  the  voltage  rating 
covered by the LVD scope is still appropriate to some or to great extent. Almost 20% (7 out of 
37)  however considered  the  voltage  limit  to  be “not appropriate  anymore”,  stating  that  devices 
powered  by  lithium  batteries  might  be  very  dangerous.  But,  safety  is  not  strictly  correlated  to 
voltage. Just over half of the stakeholders (53%) claimed that the lower bound for voltage should 
not be lowered, against a 35% of respondents stating the opposite (based on the aforementioned 
explanations  about  electrical  risks).  62%  of  the  respondents  in  the  “others”  category  expressed 

45 

 
 
their positive opinion about including in the scope of the LVD also the equipment operating at 
lower voltages. 

Overall, there is a common understanding that the listed equipment and phenomena should 
not be included in the scope of the LVD. This consensus is widely spread especially for what 
concerns  “custom  built  evaluation  kits”  (68%  responding  “No”  against  only  7%  responding 
“Yes”)  and  “electrical  equipment  for  use  in  an  explosive  atmosphere”  (63%  responding  “No” 
against 13% responding “Yes”). However, we have to reflect on a high degree of uncertainty for 
some categories: notably, for “electric fence controllers”, the number of stakeholders who did not 
have  an  opinion  is  higher  than  the  sum  of  the  respondents  in  favour  and  not  in  favour  of  the 
inclusion of the item in the scope of the LVD.  

It  should  be  noted  that  none  of  participants  who  responded  “Don’t  know”  elaborated  their 
answer. Just over one third of respondents (35%) showed uncertainty about “electricity meters”, 
and  “plugs  and  socket  outlets  for  domestic  use”  is  the  only  category  where  slightly  more 
stakeholders (80 against 70) are encouraging their inclusion in the scope of the LVD.  

This overall tendency towards the non-inclusion of the listed equipment in the scope of the LVD 
is confirmed also within manufacturers: their answers are consistent with the general trend, with 
the only difference related to “plugs and socket outlets for domestic use”. 38 manufacturers are 
not in favour to the inclusion of this item in the scope, whereas 36 are in favour and 42 of them 
do  not  have  an  opinion.  These  opinions  are  aligned  across  SMEs  and  large  companies. 
Definitions listed in Annex 2 of the LVD appeared to be the most complex question for the 
stakeholders. For every definition specified, the majority of the answers was “Don’t know”. The 
definition for which the respondents were able to give an opinion was “electrical equipment for 
use in an explosive atmosphere”. 53 stakeholders (43%) stated that the definition is well defined 
(to  a  great  or  at  least  to  some  extent)  compared  to  41  (33%)  who  responded,  “Don’t  know”. 
These opinions are aligned across SMEs and large companies. 

2.1.4 Coherence 

The overlaps in scope between the LVD and other legislation (Radio Equipment Directive 
2014/53/EU,  notably)  is  a  problematic  issue  for  43%  of  the  stakeholders  across  the 
categories (“great extent” or “some extent”). These opinions are aligned across SMEs and large 
companies. Although for the 56% this is not a problem at all, or just to a “limited extent”, there is 
room for improvement in this area.  

Clarity about the scope of the LVD has an impact on several aspects. As underlined by national 
authorities,  one  of  these  consequences  is  the  variance  in  effectiveness  of  market  surveillance 
activities across the different Member States. “Others” category considered a problem the overlap 
between LVD and other legislations: the majority of them (57%) reported this issue to some or to 
a  great  extent,  with  only  the  19%  of  respondents  stating  that  the  overlap  is  not  problematic. 
However, two thirds of respondents (62%) agreed that merging the overlapping Directives 
would not make the implementation more effective (or that implementation will be improved 
just to a “limited extent”). These opinions are aligned across SMEs and large companies. 17 out 
of  the  37  respondents  (46%)  considered  that  merging  the  scopes  of  the  LVD  and  Directive 
2014/53/EU  would  facilitate  the  implementation  of  these  legislations.  This  is  13%  higher 
compared to the 33% of positive opinions about the merger of the Directives which resulted from 
the answer of all the 221 stakeholders. 

2.1.5 Final remarks 

46 

 
 
The  final  question  for  manufacturers  asked  about  future  needs.  The  main  suggestions  for 
improvements were the following: 

  Raising  awareness  towards  simplification  of  procedures  and  about  the  importance  of 

faster standards publication in the OJEU ; 

  Greater  usage  of  e-labelling  tools  to  reduce  the  administrative  burden  related  to 

paperwork; 

  Need for stricter market surveillance (especially for products coming from outside EU) 

and better sharing of information between national authorities; 

  Possible reflection on the opportunity of merging the overlapping Directives. 

Regarding  possible  room  for  simplification66,  five  respondents  from  the  importers  and 
distributors  group  did  not  offer  any  views,  two  called  for  more  harmonisation  with  the  other 
Directives, making easier to find the right standard and to link it to the correspondent Directive. 
Finally,  two  suggested  more  clarity  for  documentation  procedures  and  only  one  encouraged  a 
narrower scope for the LVD. 

Business  and  consumer  organisations  were  also  asked  to  comment  on  any  possibilities  to 
simplify procedures linked to the LVD.67 While consumer organisations provided no comments, 
the answers of the business organisations can be summarised in three key areas of intervention: 

1.  LVD-related  procedures  are  well  designed,  but  the  management  of  all  the  processes 
should  be  improved  (e.g.  in  terms  of  effective  and  timely  communication  and 
cooperation between the economic players); 

2.  The harmonised standards discussed and adopted in compliance with the LVD should be 
published in the OJEU  immediately to avoid any delays in already lengthy process; 
3.  Online  tools  to  share  information  between  manufacturers,  organisations  and  authorities 
must  be  improved,  reducing  burdensome  paperwork  and  facilitating  the  compliance  to 
the various conformity requirements. 

All the stakeholders were asked about the overall value added of the LVD and what would be the 
consequences for their organisation, should the Directive be repealed. Overall, there is a strong 
importers,  business  associations, 
consensus  between  manufacturers,  distributors, 
authorities  and  consumer  organisations  that  there  would  be  a  very  high  risk  of  national 
fragmentation  without  the  LVD.  Given  the  positive  overall  impact  of  the  LVD,  it  was  again 
stressed  that  there  is  a  need  for  a  faster  implementation  of  international  standards  at  EU  level, 
through  the  administrative  process  required  and  the  publication  in  the  OJEU.  Also,  stronger 
enforcement of the LVD in the future is encouraged, including better cooperation between 
national market surveillance authorities to properly tackle goods coming from outside the 
EU. In respondents view, this should be possible through significant improvements in availability 
of online tools. 

2.2 Public consultation analysis 

2.2.1 Profiling questions 

The Public Consultation gathered a total of 93 replies across 17 Member States, with the highest 
number of replies from Germany and the UK. 

Figure 61 Answers to Q1. Countries of origin. 

66 Q exact phrasing: “Do you see any possibilities to simplify procedures linked to the LVD?” 
67 Q: “Do you see any possibilities to simplify procedures linked to the LVD?” 

47 

 
 
 
                                                      
Source:  Public Consultation 

Concerning  the  sample’s  level  of  knowledge  regarding  the  Directive,  the  vast  majority  of  the 
respondents deemed his/her level of knowledge of the Directive complete and detailed. Only 6 
respondents  did  not  really  know  about  the  Directive,  while  18  positioned  themselves  as  being 
aware of the Directive, but not throughout all details. 

Figure 62 Answers to Q2. Familiarity with LVD 

Source:  Public Consultation 

The  sources  of  knowledge  of  the  respondents  concerning  the  Directive  are  different. 
Respectively,  12  and  9  respondents  selected  the  products  users’  manual  and  the  media  as  the 
origin of them knowledge of the LVD. On the other hand, 66 of the respondents stated they know 
the Directive from different sources. Some of the “other sources” identified by the participants to 
the consultation were: working in a LVD-related industry, delivering training on LVD, being part 
of the national CENELEC and reading the regulation itself.  

48 

 
 
 
 
Figure 63 Answers to Q2. Sources of knowledge 

2a. Where this knowledge comes from? (n=92) 

5 

9 

12 

66 

No answer

From the media

From the users’ manual  Other

Source: Public Consultation 

2.2.2 Relevance of the LVD 

The first questions of this section attempt to map the purchasing habits of the sample’s citizens 
and  final  consumers  concerning  the  low  voltage  products  in  order  to  further  understand  the 
relevance of the scope of the Directive. 

In particular, the list of products investigated includes the following categories: 

  Computers and peripheral equipment (e.g. printers, screens, etc.) 
  Consumer electronics (e.g. televisions, DVD players, game consoles, etc.) 
  Wiring and wiring devices (e.g. cables, extenders, etc.) 
  Electric lighting equipment (e.g. chandeliers, lamps, halogen lamps for vehicles, etc.) 
  Electric domestic appliances (e.g. electric ovens, washing and drying machines, electric 
heating, fans, refrigerators and freezers, kettles, hand dryers, cooking plates, grillers and 
toasters, etc.) 

  Electrical and electronic equipment for motor vehicles (e.g. ignition wiring sets, parts of 
vehicle  starting  equipment,  distributors  and  ignition  coils,  magneto-dynamos,  manual 
welding apparatus with coated electrodes etc.) 

  Electric  motors,  generators,  transformers  and  electricity  distribution  and  control 
apparatus (e.g. generators, boards, panels, consoles, desks, cabinets and other bases for 
apparatus for electric control, etc.)  

  Other  electrical  equipment  (e.g.  parts  of  electrical  machines/apparatus  with  individual 
functions,  machines  with  translation  or  dictionary  functions,  signalling  safety  or  traffic 
control equipment for railways, roads, inland waterways, parking, etc.) 

This list  is  not exhaustive and it  has  the solely  purpose  of  helping  the respondents in  selecting 
and illustrating them purchasing activities. 

On the one hand, the participants’ answers show that consumers still purchase many of the items 
covered by the Directive. Especially, approximately the 66% of the respondents bought electric 
domestic  appliances,  electric  lighting  equipment,  consumer  electronics  and  computer  and 
peripheral equipment at least once in the past two years. On the other hand, Electrical equipment 
for motor vehicles and electric motors, generators and transformers seem not be so important in 

49 

 
 
 
 
 
consumption  habits  of  the  respondents,  considering  that  less  than  1/3  of  the  participants 
purchased one of these products in the past two years. 

Figure 64 Answers to Q4. LV products purchased 

Source: Public Consultation 

The  main  trends  reveal  that  purchasers  prefer  to  buy  low  voltage  products  online  and  in 
electric/electronic stores, while second hand transactions are the least common shopping  mean. 
Approximately the 77% of the shopping in electric stores happened in the country of origin of the 
purchasers  and  the  18%  in  another  Member  States.  The  share  of  products  bought  abroad  is 
negligent.  

Concerning  online  shopping,  nearly  the  57%  of  the  products  were  purchased  in  the  country  of 
origin,  the  25%  in  another  European  country  and  the  18%  in  another  country  outside  the 

50 

 
 
 
 
 
 
 
 
 
 
 
 
 
European  Union.  Overall,  the  participants  seem  to  prefer  buying  low  voltage  products  in  their 
countries or at least in the European Union.  

Figure 65 Answers to Q5. Purchasing habits 

Source: Public Consultation 

The  table  below  summarizes  the  extra-European  countries  were  low  voltage  items  were 
purchased  in  the  past  two  years.  The  most  quoted  countries  were  the  Asian  ones,  China  in 
particular, and the US.  

Table 6 Answers to Q5. Foreign countries where LV products were purchased 

5. If you have ticked any option in ‘in another country outside the EU’ for the question above, please 
specify in which country/countries: 

China 
Korea 
US 
India 
Switzerland 
Taiwan 
Japan 
New Zealand 
Norway 
Singapore 
Canada 

14 
2 
7 
3 
2 
1 
1 
1 
1 
1 
1 

Source: Public Consultation 

After assessing the purchasing habits of the consumers, it was assessed whether the information 
and the clarity of the Directive are still relevant to respond to consumers’ needs. 

Concerning the adequateness of the information provided with the user manuals, approximately 
the  60%  of  respondents  stated  that  safety  issues  information  are  sufficient.  In  particular,  the 
combination of one page paper on safety aspect and the digital format for the entire manual of 
instructions  were  deemed  the  more  useful  and  complete  (approximately  the  47%  of  the 
respondents),  while  the  electronic/digital  format  and  the  paper  format  alone  were  considered 
enough to provide information on safety issues only by less the 25% of the participants. Finally, 
only 28 respondents agreed that the provided manufacturer’s contact details are sufficiently clear.  

51 

 
 
 
Further,  19  participants  shared  additional  comments  on  this  question.  Relevant  suggestions 
argued  that  the  online  version  of  the  manuals  could  be  more  adequate,  because  it  could  be 
adapted by the manufacturers in the eventuality of mistakes or defects, and it is less likely to be 
lost.  However,  some  comments  stressed  that  the  level  of  quality  of  the  information  provided 
strongly depends on the product itself, and manuals of products coming from third countries are 
perceived as less complete and sufficient. Additionally, some comments stated that there is the 
need to include more safety precautions in the manuals and that the overall quality of the safety 
rules reported could be improved. Finally, some users claimed that the manufacturers’ contacts 
should be made more visible and adequate. 

Figure 66 Answer to Q8. Clarity of information provided by the user's manuals 

Source: Public Consultation 

Even though the level of information provided by the manuals was generally deemed sufficient 
by the majority of respondents, it appears that often specific information are difficult to find or 
understand. As stated above, nearly the 66% of the respondents was not able to find the contact 
details of the manufacturer, more than the 50% the contact details of the importer and the safety 
instruction, and almost the 39% the serial number of the products and the CE marking. Moreover, 
29  of  the  respondents  provided  additional  descriptions  of  situations  in  which  information  were 
difficult  to  find  or  understand.  In  particular,  it  often  emerged  that  safety  information  of 
instruction  manuals  are  missing  or  incomplete,  especially  the  ones  related  to  products  coming 
from extra European countries, as well as the information concerning the manufacturers. 

However,  it  should  be  noted  that  only  41  out  of  93  participants  to  the  survey  replied  to  this 
question, further restricting the sample and therefore limiting the room for assumptions.  

Figure 67 Answers to Q9. Information gaps 

52 

 
 
 
 
 
 
 
 
Source: Public Consultation 

Among  the  consumers  that  encountered  a  problem  in  finding  or  understanding  relevant 
information in users’ manuals, approximately half decided to not contact anyone, while 17 out of 
40 contacted the seller of the product. Only 5 respondents referred to the authorities or directly to 
the  manufacturer  specified  in  the  manual.  Finally,  only  one  person  contacted  a  consumer 
association.  

Figure 68 Answers to Q10. Contacts following unclear information 

Source: Public Consultation 

2.2.3 Effectiveness of the LVD 

Related to the effectiveness, respondents have been asked to report on situations of safety risks 
encountered while using one of the products included under the scope of the Directive. Overall, 
the almost the 26%% of the participants affirmed they have been involved in a risky situation.  

Figure 69 Answers to Q6. Situations of safety risk. 

53 

 
 
 
 
Source: Public Consultation 

All  the  24  individuals  that  replied  positively  added  detailed  descriptions  of  the  dangerous 
situation. The dangerous products were various, such as toys, electric kitchen utensils, adaptors, 
etc. Situations in which instructions were not included or the CE marking was missing were also 
described.  

Following the dangerous situation, 10 consumers decided to contact the seller of the product, 96 
the  economic  operator  specified  in  the  user’s  manual  and  7  to  not  contact  anyone  and  the 
authorities Only 1 individual contacted a consumer association. 

Figure 70 Answers to Q7. Contacts following dangerous situations. 

Source: Public Consultation 

2.3 Workshop report  

2.3.1 Understanding of the LVD 

Stakeholders agreed that there is no clear definition in the LVD of electrical equipment or of the 
types  of  products  that  should  be  considered  electrical  equipment.  Especially  in  relation  to  the 
interaction with other legislation, it sometimes creates confusion, although this is only an issue 
for a limited number of products.  

54 

 
 
 
 
The supporting documents are appreciated by the different stakeholders. Where the Directive is 
sometimes  written in a  less  clear  way,  the  guidelines  provide explanations,  which  are  easier to 
understand  and  to  follow.  Some  were  of  the  opinion  that  this  clarity  is  also  needed  in  the 
legislation and not only in the guidance and that the LVD wording should be further aligned with 
the new legislative framework. 

One  source  of  confusion  for  the  LVD  scope  are  sets  of  products  that  are  intended  to  be  used 
together,  such  as  peripheral  products  for  computers. One  example  provided  by  the  AdCo  chair 
was  that  of  solar  panels,  which  separately  have  very  low  voltage  but  when  used  together  fall 
within the voltage range. The AdCo group made a point that they would want a revision to make 
a clear decision on how these products should be considered. 

In  terms  of  innovation  and  new  risks,  since  the  LVD  uses  very  general  language,  most 
stakeholders  were  of  the  opinion  that  the  Directive  covers  all  types  of  innovation  and/or  new 
safety risks. While some argued for using more explicit language, others pointed to the risk that 
more specifications make it also more likely that you miss something.  

2.3.2 Interaction with other legislation 

Stakeholders  brought  up  the  interaction  with  the  RED  and  its  effect  on  the  scope  of  the  LVD. 
Differences between the types of products used to be significant but are now increasingly blurred 
(e.g. home appliances with WIFI connections), making it unclear which directive applies. While 
the  number  of  these  “grey  areas”  are  currently  still  limited,  economic  operators  foresee  more 
problems  10  years  ahead  as  “eventually  all  products  will  be  products  under  RED.”  Economic 
operators also raised the related issue that is it is not clear who decides: there is no authority to 
give a final decision under which Directive the product should fall. There is confusion about why 
RED  covers  LVD  aspects,  as  safety  is  not  a  main  topic  of  RED.  Some  attendees  stated  that 
directives should be geared at different types of risks rather than being product-specific.  

The interaction with the MD was also mentioned. Certain product categories are mentioned in the 
MD but not defined, which creates some (incidental) confusion as to when to take the end use as 
domestic or industrial (e.g. with laundry machines or 3d printers).  

The standards used for complying with the LVD and RED are “practically the same”. The only 
difference  is  the  declaration  of  conformity  that  has  to  be  provided.  This  creates  problems  for 
economic  operators  because  if  it  is  not  fully  clear  under  which  Directive  a  product  falls  (grey 
area)  they  have  to  make  a  choice,  which  does  not  guarantee  that  all  Member  States  will  agree 
with their interpretation, which may require additional administrative costs.  

While  the  idea  of  merging  directives  came  up  in  several  rounds  there  was  no  consensus,  the 
majority of stakeholders (especially business) dismissed this idea because of the complications it 
would create (e.g. clarity to economic operators).  

2.3.3 Implementation of the LVD 

Participants  validated  that  the  LVD  could  be  considered  as  best  practice  in  terms  of  product 
legislation. It is considered well-functioning and fit for purpose even if it still can be improved.  

Discussions  among  participants  confirmed  standards  should  be  considered  as  key  elements  in 
relation  to  the  implementation  of  the  LVD.  Recent  policy  developments  including  European 
Court of Justice case law leave room for stakeholders to reinterpret the voluntary characteristic of 
standards.  In  this  regard,  some  stakeholders  feel  the  use  of  standards  has  actually  become 
mandatory for economic operators willing to ensure compliance of their products with regards to 
the  LVD.  In  this  context,  a  participative  approach  to  standardisation  at  EU-level  is  ever  more 

55 

 
 
crucial  to  ensure  the  effectiveness  of  the  standardisation  procedures.  However,  while  in  theory 
the  delegation  principle  ensures  that  any  stakeholder  may  participate  in  standardisation 
committees, it appears that in practice this may be hindered by a lack of resources. 

The  implementation  of  the  current  conformity  assessment  procedure  (Module  A)  was  also 
discussed. Participants highlighted the importance and effectiveness of leaving full responsibility 
to  economic  operators  to  ensure  the  implementation  of  the  essential  safety  requirements  in 
practice,  even  if  this  implies  that  there  is  a  possibility  of  diverging  practices  among  economic 
operators. Some participants also felt there is a lack of definition of risks and related assessment 
procedures,  which  could  lead  to  some  not  being  included  in  the  tests  conducted  by  companies 
under the current conformity assessment procedure. 

In this regard, it was mentioned that no other module68 would eliminate the issue of uncompliant 
products  or  fraudulent  economic  operators,  which  depend  on  the  effectiveness  of  market 
surveillance activities. The removal of notified bodies from the implementation of the LVD was 
seen as a positive development, which should not be undone.  

Regarding the EU Declaration of Conformity, it was discussed that the interaction of most low 
voltage products with other legislation, including RED, EMCD and MD, is burdensome without 
necessarily adding value in terms of safety. As for the CE marking, it was discussed that while it 
represents the final compliance  milestone  for  industry  stakeholders,  it  is  not  a  label targeted  at 
consumers, and therefore should not be promoted as such.  

The  implementation  of  the  provisions  related  to  labelling  and  (technical/safety)  documentation 
were  also  discussed  by  participants.  While  it  was  confirmed  that  these  are  somewhat  outdated 
and not following the current trends in digitalisation, the traceability of products these offer was 
highlighted  as  a  crucial  aspect  for  national  authorities  and  consumers.  However,  it  was  also 
mentioned  that  physical  marking  and  documentation  may  be  contain  falsified  information,  e.g. 
‘letter  box’  company  addresses,  which  therefore  hinder  the  traceability  to  the  same  extent  that 
electronic labelling or marking. 

Electronic  labelling  (on  product  screens)  and  marking  (through  barcodes,  DR  codes,  website 
addresses,  etc.)  were  discussed  as  being  solutions  to  cater  to  issues  relating  to  the  smaller  and 
smaller  size  of  products.  The  establishment  of  an  electronic  product  record  database  was 
discussed  in  order  to  resolve  the  traceability  issue  related  to  electronic  marking  of  goods. 
However,  the  burden  related  to  its  updating,  maintenance  and  governance  was  raised  as  a 
challenge. 

Finally,  it  was  highlighted  that  accompanying  goods  with  their  technical  documentation  and 
safety  instructions  is  a  burden  for  economic  operators  and  it  creates  (in  some  instances, 
unnecessary) waste. However, it was underlined that this allows consumers to always have direct 
access  to  such  crucial  information  (as  opposed  to  having  these  in  an  electronic  format,  which 
requires ICT literacy from consumers). 

Concerning  the  implementation  of  low  voltage  product  legislation  in  third  countries  (including 
Argentina, Canada, China, Japan, South Korea and the USA) it was mentioned that international 
(IEC) standards were referred to and applied broadly all over the world (with some slight national 
adaptations when necessary).It was mentioned that the culture governing product safety, related 
legislation and compliance by economic operators differs from country to country. The USA was 

68  E.g.  Module  B,  for  which  it  was  underlined  that  it  could  not  be  compared  to  a  bundle  of  ‘Module  A 

topped with notified bodies’ as its overall requirements and related burden go far beyond that. 

56 

 
 
                                                      
mentioned  as  an  example  where  the  public  is  incentivised  to  legally  pursue  uncompliant 
economic  operators  (as there  is  often  large  sums  of money  linked  to liability), whereas  there  a 
significantly fewer of such cases in Europe. 

It was mentioned that China has recently removed notified bodies from the certification processes 
for some electrical products, and has also moved on with electronic labelling, together with the 
USA. 

2.3.4 Enforcement of the LVD 

Discussions provided insights especially about the first two suggested points of discussion. Less 
was  said  about  market  surveillance  practices  in  non-EU  countries,  however  a  trade  association 
explained that the US system is not well developed, whereas in the Gulf Region, in Australia and 
in Asia (especially Japan and South Korea) strict requirements (comparable to the EU ones) are 
in place. 

On  products  coming  in  from  outside  the  EU,  it  was  also  noted  that  non-compliant  products 
cannot be effectively stopped at customs for multiple reasons: the customs officers do not have 
the relevant knowledge/training, their focus is on stopping illegal and unlabelled rather than non-
compliant products, and they do not have the capacity to examine the content of every shipment.  

About the impact of variances in market surveillance activities across EU Member States, there 
was an overall consensus from all stakeholders that national budget constraints are a widespread 
issue  across  the  EU  (with  the  remarkable  exceptions  of  Finland  and  Denmark).  This  prevents 
national market surveillance authorities from performing sufficient in-depth product testing on a 
large scale, potentially highlighting a gap between formal compliance with the LVD and actual 
effectiveness of the safety provisions included in the Directive. 

A few options have been suggested this; some EU Member States and some (both consumers and 
industry)  associations  have  suggested  more  cooperation  with  the  various  industry  players,  in 
order  to  efficiently  share  the  burden  between  the  authorities  and  the  manufacturers,  as  well  as 
efficient  sharing  on  information  between  Member  States.  It  was  also  noted  that  the  Goods 
Package might improve the situation to some degree. 

In terms of testing approach, the opinions between EU Member States were somewhat different, 
with  one  EU  Member  State  suggesting  the  implementation  of  “market  share”  testing  (already 
compulsory within the scope of the Automotive Directive): the amount of tests to be performed 
being  linked  to  the  market  share  of  the  item  sold  in  each  country,  thus  the  higher  the  market 
share,  the  higher  the  number  of  tests  which  the  product  would  need  to  pass.  Whereas  two 
Member States proposed a “risk-based” approach towards testing, allocating the limited resources 
for testing to the higher risk categories of products. The importance of randomised testing was 
also highlighted. 

Another  relevant  issue  is  the  cooperation  and  communication  at  intra-EU  borders.  Several 
stakeholders  suggested  that  more  efforts  should  be  put  in  place  to  avoid  the  practice  by 
manufacturers  of  trying  to  sell  non-compliant  items  at  different  national  borders,  after  having 
already been rejected by the customs in one Member State. A push towards e-labelling and the 
use of an electronic registry for non-compliant products are two encouraged measures to tackle 
this  issue.  However,  according  to  a  trade  association,  even  with  national  variances  in 
surveillance, there is no common perception among manufacturers that the single internal market 
is segmented in “easily accessible” markets (with lower safety standards) and markets “accessible 
only  with  difficulty”:  the  EU  single  internal  market’s  safety  standards  are  still  considered 
efficient in the whole area. 

57 

 
 
Overlapping  with  the  issue  of  budget  constraints,  another  debated  topic  was  the  interaction 
between the LVD and other similar Directives. One Member State encouraged a reflection about 
the merger of RED and LVD, while some other Member States as well as associations were in 
favour  of  the  distinction  between  LVD  and  RED.  Other  Member  States  also  warned  about 
possible administrative burden resulting from a potential new unified Directive.  

Some stakeholders also expressed dissatisfaction with the fact that introducing Wi-Fi connection 
automatically moves an appliance from the LVD scope to RED scope. It was considered that in 
many cases this does not really make sense, as the potential safety risks of those products remain 
largely the same, relating to their LVD related aspects rather than IoT aspects.  

A final element highlighted was the impact of not having a notified body provision in the LVD 
text: according to two Member States, Notified Bodies could be a source of support and guidance 
for SMEs struggling with the conformity assessment process, or in cases of conflict with Market 
Surveillance Authorities.  

It  was  also  suggested  that  Notified  Bodies  could  be  brought  back  specifically  for  innovative 
and/or particularly complicated or high-risk products, or the choice of module could be left to the 
manufacturer,  depending  on  their  need  for  external  support.  One  industry  association  also 
suggested that involvement of Notified Bodies would not improve compliance, as manufacturers 
willing to comply will do so in any case, and manufacturers not willing to comply will find their 
ways around.  

2.3.5 LVD Working Party attendees 

Here below are the LVD Working Party list of attendees. 

National authorities 
  Germany  
  Malta 
  Norway   
  Poland 
  Slovakia 
  United Kingdom 
  Belgium 
  Czech Republic 
  Denmark  
 
Ireland 
  Spain 
  Switzerland 
  Finland 
  France 
 
Italy 
  Lithuania 
  Netherlands  
  Sweden 

Industry associations 

Consumer organisations 

Standardisation bodies 

  ANEC 

  CEN-

CENELEC 

  CLEPA 
  European 
Leagues 
  European 

Cancer 

Sunlight 

Association 
  Lighting Europe 
  Orgalim 
  Applia  
  EGMF 
  CECAPI  
  CECIP 
  EuroCommerce  
  Digital Europe 

58 

 
 
 
 
 
 
 
ANNEX 3  

METHODS AND ANALYTICAL MODELS 

The evaluation study was conducted from June 2018 to June 2019, with data collection activities 
running until April 2019. Data was gathered through the following means: 

-  Desk  research  by  analysing  previous  evaluations  and  impact  assessments  of  the  LVD, 
legislative and guidance documents, LVD working party and AdCo documents, existing 
reports  and  studies  on  the  electrical  equipment  industry  and  related  market  trends  and 
database  extracts  from  Eurostat,  the  Rapid  Alert  System  for  Dangerous  Non-Food 
Products (RAPEX) and received from national authorities. (see Annex 6 for more details) 

- 

Interviews  with  stakeholders  such  as  National  authorities,  Businesses  &  industry 
representatives  (incl.  innovation  hubs),  Standardisation  bodies,  Consumers  and  Third 
country stakeholders. 

-  Public  Consultation  addressed  to  all  categories  of  stakeholders  and  in  particular  EU 
citizens and civil society. It was aimed at gathering factual information, data, knowledge 
and perception by final consumers and citizens across the EU about the LVD. 

-  Stakeholder surveys  targeting  notably  businesses in  all  28 MS,  Business and consumer 

associations, Standardisation bodies, National authorities and consumers. 

-  Workshop  which  was  organised  on  8  February  2019  in  Brussels.  The  purpose  was  to 
discuss the preliminary findings around understanding, implementation and enforcement 
of the LVD. 

The figure below provides an overview of the approach to the study  

Figure - Approach to the study 

59 

Phase I: Inception PhasePhase II: Data collectionProject Management and Quality Assurance Kick-off meeting, Inception Report MeetingStrategicinterviewsRefinement of the methodological approach (incl. Intervention logic, analytical framework and data collection toolsof available documents and desk/data research)Desk researchFieldwork and phone interviewsPhase III: Final analysis and reportingMarket analysisCase studiesPhasesandtasksDeliverablesData collectionInception reportInterim ReportInterviewsDesk researchOpen Public ConsultationWorkshop with industryFinal Study ReportPreliminary desk researchPublic consultation (drafting , analysis & reporting)Data analysis/case studies Compiling indicators (AF) Stakeholders’ surveysDraft FinalreportSurveysFieldwork/case studies Cost-benefit / Cost-effectiveness analysisCost-benefit/ Cost-effectiveness analysisMarket analysisStandard CostModelConclusions and RecommendationsFirst ProgressReportSecond ProgressReportWorkshop with industryInterim Report MeetingFinal Report Meeting 
 
 
Source: Consortium 

The  figure  below  provides  an  overview  of  the  intervention  logic  of  the  LVD  that  was  used  to 
identify the evaluation questions  

Figure - Intervention logic 

Source: Consortium 

3.1 Data collection and consultation strategy 

The evaluation study was conducted from June 2018 to June 2019, with data collection activities 
2019, 
running 

April 

until 

60 

SpecificobjectivesActivities/ actionsGeneral objectivesEnsure internal market for equipment in the scope, by preventing obstacles to the free movement of such equipment Ensure that electrical equipment placed in the EU market provides high level of protection of health and safetyof persons or domestic animals and to propertyOutputsNeeds Supporting the achievement of the full potential of the Internal Market Protecting the health and safety of citizens, animals and property Ensuring harmonisationof rules and procedures  across the EUEnsuring fair competitivenessin the sectorPreventing non-compliant electrical equipment to be placed on the EU marketInputsHarmonised standards for electrical equipment across the EU Essential requirements addressing the safety objectives, covering risks and health aspectsProvision of guidance(Guidelinesfor the application of the  LVD, Papersfrom LVD Electrical Committee and LVD Working Party, Reportsfrom Administrative Cooperation (ADCO)Conformity assessment procedures  must demonstrate that health and safety objectives have been achievedApplication of harmonised standards for presumption of conformity by manufacturers (voluntary)Application of essential requirements addressing the health and safety objectives  by manufacturers Monitoring of application of harmonised standards and conformity assessment procedures by Member States Enforcement mechanisms  at EU level (Electrical Committee and LVD working Party) and in Member States (ADCO)CE markingEU declaration of conformityTechnical documentationExpected results Safetyof products on the EU marketFree circulation in the Internal market pf products in scopeHamonisedimplementation of standards and  procedures across the EUTimely identification and removal of non-compliant products across the EU  
 
  
 
 
 
 
 
 
 
3.1.1 Desk research 

As presented in the figure above, desk research was a continuous activity during the supporting 
evaluation study.  A series of insightful documents were recapped and analysed such as: 

  Previous  evaluations  and  impact  assessments  on  the  LVD  as  well  as  other  EU 

instruments such as the market surveillance Regulation; 

  Legislative and guidance documents on LVD and other legislation linked to the scope of 

this evaluation; 

  LVD Working Party and AdCo (public and restricted CIRCAB) documents; 

  Existing  reports  and  studies  on  the  electrical  equipment  industry  and  related  market 

trends, 

  Database  extracts  from  Eurostat,  the  Rapid  Alert  System  for  Dangerous  Non-Food 

Products (Safety Gate/RAPEX) and received from national authorities, etc. 

The desk research allowed to gather inputs notably on: 

  The functioning of the LVD, its strengths and weaknesses, as well as key topics on the 

agenda of related working groups. 

  The functioning of other instruments applying to products in the scope of the LVD 

  The low voltage product market, its economic operators and evolution over the years 

  The number of uncompliant products reported over time in the EU. 

3.1.2 Interviews 

A significant number of interviews were carried out as part of the consultation activities. These 
were  conducted  with  different  types  of  stakeholders,  at  both  EU  and  national  level.  Also 
stakeholders from third countries were interviewed in order to complement the understanding of 
legislative systems for low voltage products in other regions of the world, and possibly spot ‘best 
practices’ (presented in Annex P of the evaluation study). The table below provides the overview 
of the types of stakeholders consulted throughout all interviews carried out in the context of this 
evaluation. Annex D of the evaluation study presents the interview guides for each type of semi-
structured conversations and Annex 6 contains the list of interviewees. 

61 

 
 
 
3.1.2.1 Strategic and EU-level stakeholders interviews 

Between  July  and  November  2018,  9  EU-level  stakeholders  were  interviewed,  as  presented  in 
Table  1  above.  These  interviews  contributed  notably  to  the  mapping  of  processes  related  to 
obligations set by the provisions of LVD to each type of stakeholder, as well as the identification 
of the type of costs and benefits associated with these processes. 

Organisation 
LVD AdCo 
ANEC 
APPLIA 
CENELEC - CCMC 
CENELEC – LVD Technical Committee (BTWG143-1) 
Digital Europe 
Lighting Europe 
LV WP chair 
Orgalim 

Date  
21/09/2018 
29/11/2018 
11/09/2018 
19/07/2018 
18/09/2018 
13/09/2018 
13/09/2018 
25/09/2018 
11/09/2018 

Moreover,  they  provided  more  insights  into  the  safety  aspects  as  well  as  into  the  relations 
between the LVD and other Directives. They also allowed to raise these interviewees’ attention 
to  the  stakeholder  survey  and  subsequently  requesting  them  to  act  as  multipliers  by  sharing  its 
link  among  their  relevant  contacts.  Furthermore,  some  of  these  interviewees  also  provided 
relevant documentation and potential interview contacts at Member State level for the fieldwork 
interviews. 

During  LVD  Advisory  Committee  (AdCo)  meeting  that  took  place  in  Leuven  on  5  December 
2018, the objectives and focus of the evaluation were presented, an overview of the methodology 
and  the  status  to  date  of  the  assignment.  Further,  a  set  of  questions  and  topics  were  discussed 
with  the  AdCo  members.  The  participation  to  the  meeting  namely  contributed  to  the  better 
understanding of the views of the EU Member States. 

3.1.2.2 National-level stakeholder interviews 

Fieldwork  was  conducted  in  six  selected  Member  States  (Czech  Republic,  Germany,  Finland, 
France, Italy and Poland) between end November 2018 and early February 2019. Interviews (up 
to 10 in each country) were organised in order to include the following types of stakeholders: 

62 

 
 
 
 
 
Results 

  Businesses:  Businesses  were  chosen  so  as  to  ensure  a  mix  across  the  value  chain  and 
business  size  (i.e.  larger  businesses  and  Small  and  Medium-sized  Enterprises  (SMEs) 
making  sure  to  cover  the  five  main  product  groups  in  the  scope  of  the  Directive.  In 
particular,  two  product  groups  based  on  the  second  revision  of  the  Statistical 
classification of economic activities in the European Community (NACE Rev.2, derived 
from 
la 
Communauté européenne). NACE Rev.2 per Member State were selected as focus: 

the  French  Nomenclature  statistique  des  activités  économiques  dans 

-  Czech Republic: C26.2 (Manufacture of computers and peripheral equipment), C27.1 
(Electric  motors,  generators,  transformers  and  electricity  distribution  and  control 
apparatus) 

-  Germany:  C26.2  (Manufacture  of  computers  and  peripheral  equipment),  C27.1 
(Electric  motors,  generators,  transformers  and  electricity  distribution  and  control 
apparatus); 

-  Finland: C27.1 (Electric motors, generators, transformers and electricity distribution 

and control apparatus), C27.5.1 (Electric domestic appliances); 

-  France: C27.4 (Electric lighting equipment), C27.5.1 (Electric domestic appliances) 

- 

Italy: C27.4 (Electric lighting equipment), C27.9 (Other Electronic equipment) 

-  Poland: C27.5.1 (Electric domestic appliances, C27.9 (Other Electronic equipment) 

First,  the  stakeholders  were  mapped  to  include  economic  operators  from  relevant  sectors  and 
eventually  shortlisted  larger  businesses  and  SMEs  (at  least  1  in  each  Member  State), 
manufacturers,  importers  and  distributors.  The  interviews  themselves  focused  on  gathering 
information  on  the  compliance  and  administrative  costs  that  firms  face  when  complying  with 
LVD-related provisions. 

  National  authorities:  Similarly,  in-depth  interviews  were  conducted  with  the  relevant 
national  authorities  in  charge  of  monitoring  and  enforcing  the  LVD  on  the  national 
territory. In the case of the Federal State of Germany, where the enforcement of federal 
legislation  and  market  surveillance  is  a  competence  of  the  subnational  administrative 
units (16 federal states), in addition to the market surveillance central point of contact, an 
additional contact conveying the subnational priorities and tasks in the field of LVD was 
interviewed. 

  European  Committee  for  Electrotechnical  Standardization  (CENELEC)  Committees: 
representatives  of  CENELEC  Members  of  the  National  Electrotechnical  Committees 
entrusted with electrotechnical standardisation were interviewed. 

  National business and consumer associations: of relevance to the study in order to further 
explore the effects of the LVD on companies and consumers (up to 1 in each Member 
State). 

Overall, this activity allowed to collect information on issues regarding the implementation of the 
LVD,  the  current  status  of  the  market  including  any  trends,  international  benchmarks  or  best 
practices  that  the  interviewees  considered  relevant,  and  to  collect  additional  sources  of 
information.  In  order  to  best  coordinate  the  additional  data  collection  activities  (e.g.  open 

63 

 
 
stakeholder’s  survey,  fieldwork  and  phone  interviews  in  six  selected  Member  States),  it  was 
made sure to tap into the stakeholders’ contacts in EU Member States. 

The table below provides an overview of the fieldworks, per country and type of stakeholder: 

3.1.2.3 Third country stakeholder interviews 

In order to complement the information available through other data collection activities on the 
regulatory systems for electrical equipment in third countries two interviews with third country 
stakeholders were carried out. 

These interviewed allowed to: 

  Finetune  the  understanding  of  regulatory  systems  in  place  for  low  voltage  products  in 
USA, Canada, China, South Korea, Japan, Argentina, thereby allowing to compare them 
with the LVD. 

  Understand how third countries deal with aspects that are considered as the shortcomings 

of LVD, thereby possibly identifying best practices. 

3.1.3 Surveys 

Two  online  consultations  were  carried  out  as  part  of  the  evaluation:  the  targeted  stakeholder 
survey, with differentiated questions per type of stakeholder, and the Public Consultation (Public 
Consultation) with one set of questions available for all respondents. 

3.1.3.1 Stakeholder survey 

The stakeholder survey was set up on EU Survey and launched online on 4 December 2018. Its 
initial closure data was planned on 15 January 2019, however, it was extended until 31 January 
2019  in  order  to  maximise  the  response  rate  over  the  holiday  period.  The  stakeholder  survey 
targeted notably: 

64 

 
 
 
  Businesses  (both  larger  businesses  and  SMEs)  in  all  EU  28  Member  States,  including 
manufacturers, importers and distributors of electrical products in the scope of the LVD; 

  Business and consumer associations (including innovation hubs and incubators) in EU 28 

Member States; 

  Standardisation bodies: national standardisation committees for low voltage products in 

all Member States; 

  National  authorities  in  EU  28  Member  States:  e.g.  national  authorities  that  are 

responsible for the implementation of the LVD and related market surveillance; 

  Consumers in all 28 EU Member States. 

Dissemination was carried out through several channels, in order to maximise the outreach of the 
target population and thus the number of answers: the link was shared with all interviewees (EU 
level  stakeholders  as  well  as  fieldwork  interviewees),  asking  them  to  disseminate  the  survey 
among  their  members/contacts,  triggering  all  dissemination  channels,  including:  social  media 
pages  (e.g.  LinkedIn,  Twitter  account  of  those  organisations),  organisations’  websites  and 
newsletters, etc. DG GROW shared the link on its website, and on the respective intranets for the 
LVD Working Party and AdCo11. 

In  total,  221  responses  were  received  for  this  survey.  Of  these,  116  were  manufacturers,  10 
importers and distributors, 13 National Authorities including market surveillance authorities, 40 
business associations, 4 consumer organisations, and 38 reported as belonging to “others” group. 
The last category included, among others, testing and standardisation organisations, present and 
former  notification  bodies,  consultancies  and  academic  and  educational  organisations.  The 
highest  number  of  stakeholders  participating  in  the  survey  was  from  Germany  (70),  including 
German manufacturers. 

3.1.3.2 Public consultation 

As  per  the  Better  Regulation  Guidelines  (BRG),  the  European  Commission  launched  a  Public 
Consultation  on  10  January  2019,  which  was  online  for  the  mandatory  period  of  12  weeks 
(closure  on  4  April  2019).  The  Public  Consultation  questionnaire  (provided  in Annex  H  of the 
evaluation  study)  included  general  questions  addressed  to  all  EU  citizens.  It  was  aimed  at 
gathering  factual  information,  data,  knowledge  and  perception  by  final  consumers  and  citizens 
across the EU about the following aspects of the LVD: 

  Relevance  of  the  scope  and  the  objectives  of  the  LVD  compared  to  the  needs  of  the 

consumers; 

  Effectiveness of the Directive in ensuring consumers’ safety. 

The Public Consultation was mainly disseminated through a link on DG GROW’s website. The 
Public  Consultation  gathered  a  total  of  93  replies  across  17  Member  States,  with  the  highest 
number of replies from Germany and the UK. 

3.1.4 Workshop 

A  validation  workshop  was  organised  on  8  February  2019  in  Brussels.  The  purpose  was  to 
discuss the preliminary findings around the three topics outlined below with the LVD Working 
Party prior to their validation: 

65 

 
 
  Understanding of the LVD, i.e. regarding the clarity of the Directive, its objectives and 

requirements, scope, provisions, etc.; 

 

Implementation  of  the  LVD,  i.e.  regarding  the  day  to  day  functioning  of  the  Directive 
and  the  way  it  is  applied  (e.g.  use  of  standards,  implementation  of  the  conformity 
assessment procedure and CE marking, labelling requirements, etc.); and, 

  Enforcement  of  the  LVD,  i.e.  regarding  the  extent  to  which  it  is  actually  adhered  to, 
market surveillance activities at national-level, (e.g. availability of resources, processes, 
results of market surveillance and safety, etc.). 

Annex  5  contains  the  agenda  and  list  of  participants  of  the  workshop  and  Annex  K  of  the 
evaluation study reports on the main conclusions of the workshop. 

3.2 Methodology to identify the products in the scope of the LVD  

The challenge for the data collection and analysis is that low-voltage products are not a defined 
sector  in  the  industry  and  are  also  not  recorded  as  a  separate  group  of  products  in  statistical 
databases. As a result, assumptions need to be made to define the low voltage sector in relation to 
market  data.  This  section  presents  the  methodology  and  main  assumptions  made  for  data 
analysis. 

The market analysis is based on a selection of nine NACE Rev.2 categories describing economic 
activities of the manufacture of electrical equipment. These nine categories are the ones defined 
in  the  2005  Impact  Assessment69  (with  the  update  to  NACE  Rev.2)  and  were  reviewed  by 
technical  experts  to  ensure  these  categories  still  cover  the  totality  of  the  electrical  equipment 
currently in the market. Table below introduces these specific categories: 

NACE code 
C26.2 
C26.3 
C26.4 

Table  – NACE categories of products under the scope of the LVD 
Category name 
Manufacture of computers and peripheral equipment  
Manufacture of communication equipment 
Manufacture of consumer electronics  
Manufacture  of  electric  motors,  generators, 
distribution and control apparatus 
Manufacture of wiring and wiring devices  
Manufacture of electric lighting equipment 
Manufacture of electric domestic appliances   
Manufacture of other electronic equipment 
Manufacture of electrical and electronic equipment for motor vehicles 

C27.3 
C27.4  
C27.5.1  
C27.9 
C29.3.1  

C27.1  

transformers  and  electricity 

The  manufactured  products  described  in  the  NACE  categories  contain  products  falling  both 
within and outside the scope of the LVD. Therefore, as a next step, the more detailed Prodcom-
level product list for each of these NACE categories were used to apply specific criteria to define 
whether each product category is likely to fall within the scope of the LVD. To fall within the 
scope of the LVD, a product category has to comply with the following criteria: 

  Product refers to electrical equipment; 
  Product falls within the voltage limits set by the LVD; 
  Product is not part of the exceptions included in the LVD; and 

69 Impact Assessment of Various Policy Options for a Possible Amendment of the LVD (2005) 

66 

 
 
 
                                                      
  Product  that  is  not  excluded  from  the  LVD  because  it  falls  under  other  relevant 
Directives (such as the Radio Equipment Directive or the Machinery Directive).70  

Within  the  nine  NACE  categories,  188  product  categories  comply  with  the  criteria  set  out.  It 
should be noted that it is not possible to have a clear conclusion for each product category. This 
is  because  these  categories  consist  of  a  mix  of  products,  and  these  products  can  be  within  or 
outside the scope of the LVD, depending on the specific product characteristics. Therefore each 
product  category  was  assessed  for  whether  the  products  it  contains  are  likely  to  be  within  or 
outside the scope of the LVD, or whether this depends on product characteristics not reflected in 
the code’s label (mixed).  This allows us to present a ‘minimum’ range of products that are within 
the scope of the LVD, and an ‘additional’ range of products that can be either within or outside 
the scope of the LVD. Together, these categories constitute the maximum range of products that 
are covered by the LVD.  

It should be noted that the analysis of whether a product category classifies as within the scope or 
not is based on the current state of play (i.e. the situation at the time the study was conducted), 
both  with  respect  to  the  product  characteristics  and  the  policy  and  regulatory  setting.  This 
assessment could therefore change over time, with developments in technologies and the policy 
landscape.   

For  trade  data,  products  are  grouped  based  on  Harmonized  System  codes  (the  international 
nomenclature  for  the  classification  of  product)  on  a  level  of  six  codes.  HS6  codes  are  slightly 
more  general  than  Prodcom  codes  but  can  be  matched  using  conversion  tables,  with  an 
equivalence  of  150  HS  codes  to  188  Prodcom  codes.  It  is  important  to  highlight  some  issues 
related  to  the  underlying  data,  that  should  be  taken  into  account  in  the  interpretation  of  the 
results. First, many product categories start recording values at different years, and the growth in 
trade  may  therefore  be  partly  be  due  to  better  data  availability  in  recent  years.  Secondly,  data 
presented is for all current EU countries over time, to keep the number of countries constant and 
thus to separate trends in increased trade from EU enlargement. This means that trade with the 
countries  that joined the  EU  after  2000 can therefore  not  be  considered  as  intra-EU  trade  until 
their actual accession. 

3.3 Methodology for the analysis of Safety Gate/RAPEX data 

Data on dangerous products falling under the LVD was collected from the Rapid Alert System 
for dangerous non-food products (Safety Gate/RAPEX) and visualised using Microsoft Excel.  

Safety  Gate/RAPEX  enables  a  quick  exchange  between  30  countries  and  the  European 
Commission on measures taken against dangerous non-food products posing risks to the health 
and  safety  or  environment  or  any  other  aspect  of  public  interest  protection  of.  The  system 
contains all records of notifications since the creation of the system in 2004.  

While the public search functionality of Safety Gate/RAPEX71 does not include a filter to select 
by  Directive,  the  free  text  field  was  used  to  identify  those  products  that  were  reported  as  not 

70 Certain directives which cover equipment that also falls under the scope of the Low Voltage Directive 
explicitly state the Low Voltage Directive is not applicable for this equipment. For example, the LVD 
does not apply to products covered by the RED. Products which meet the definition of radio equipment 
and  fall  under  the  scope  of  the  are  explicitly  excluded  from  the  LVD.  Therefore,  where  RED  is 
applicable to radio equipment, the LVD does not apply. 

67 

 
 
 
                                                      
complying with the LVD (using the search term “Low Voltage Directive”) Therefore, the list of 
alerts  did  not  include  any  products  that  would  have  been  reported  to  be  in  violation  by  a 
particular European standard only.  

By 3 December 2018, alerts were submitted for 3,223 products covered by requirements of the 
LVD.  The  highest  number  of  such  alerts  was  submitted  in  2013  (286  measures  reported).  It 
should  be  noted  that  the  data  submitted  to  Safety  Gate/RAPEX  depend  on  surveillance  and 
reporting practices and frequency, which vary between countries and also between years within a 
given country. Therefore, the data from year to year are not directly comparable. 

The categories used by Safety Gate/RAPEX differ from the ones used in the economic analysis 
of this study. The RAPEX categories coinciding with LVD products for which there were alerts 
were the following: 

  Communication and media equipment 
  Electrical appliances and equipment 
  Gadgets 
  Kitchen/cooking accessories 
  Laser pointers 
  Lighting chains 
  Lighting equipment 
  Protective equipment  
  Other 

The  most  commonly  reported  Safety  Gate/RAPEX  category  for  which  reference  to  non-
compliance  with  the  LVD  is  made  is  electrical  appliances  and  equipment  (55%  of  such  alerts 
over  2005-2018),  which  includes  equipment  such  as  small  kitchen  appliances  and  home 
electronics, cables, chargers and adapters, and hand tools. As the type of equipment is manually 
entered, doing precise calculations per equipment type is practically impossible due to different 
ways of entering the same type of equipment (e.g. different spellings and misspellings, inclusion 
or non-inclusion of the specific brand, plural or singular form, use of quotation marks, etc.).  

It  appears  that  76%  of  the  measures  on  products  covered  by  the  requirements  of  the  LVD 
products reported originated from China across the years. From 2009 onwards, the share of such 
measures on Chinese products has remained in the range of 79% to 89% each year. China is the 
EU’s  largest  trade  partner  of  LVD  products,  which  partially  explains  the  prevalence  of  unsafe 
faulty Chinese products reported in Safety Gate/RAPEX.  However, due to the limitations of data 
from Safety Gate/RAPEX, these results cannot be extrapolated to the internal market in general. 

71 Search tool available from Safety Gate website on 

https://ec.europa.eu/consumers/consumers_safety/safety_products/rapex/alerts/?event=main.search&lng=en . Note 
that this data concerns publicly available information only. 

68 

 
 
 
 
 
 
 
 
 
 
                                                                                                                                                              
ANNEX 4 

ANALYSIS OF THE LVD MARKET 

NACE categories of products under the scope of the LVD 

NACE code 
C26.2 
C26.3 
C26.4 

C27.1  

C27.3 
C27.4  
C27.5.1  
C27.9 
C29.3.1  

Category name 
Manufacture of computers and peripheral equipment  
Manufacture of communication equipment 
Manufacture of consumer electronics  
Manufacture  of  electric  motors,  generators, 
distribution and control apparatus 
Manufacture of wiring and wiring devices  
Manufacture of electric lighting equipment 
Manufacture of electric domestic appliances   
Manufacture of other electronic equipment 
Manufacture of electrical and electronic equipment for motor vehicles 

transformers  and  electricity 

Production of low voltage products (million euro), 2017 

NACE code 

C26.2 

C26.3 

C26.4 

C27.1  

C27.3 

C27.4  

C27.5.1  

C27.9 

C29.3.1  

of 

of 

of 

and 

computers 

communication 

Category name 
Manufacture 
peripheral equipment  
Manufacture 
equipment 
Manufacture of consumer electronics  
Manufacture 
electric  motors, 
generators,  transformers  and  electricity 
distribution and control apparatus 
Manufacture  of  wiring  and  wiring 
devices  
Manufacture 
equipment 
Manufacture  of 
appliances   
Manufacture 
equipment 
Manufacture of electrical and electronic 
equipment for motor vehicles 

electric  domestic 

electronic 

lighting 

electric 

other 

of 

of 

Total production 

Minimum LVD 

Additional LVD 

€     94,856 

€                   - 

€          16,819 

€    33,346 

€    20,847 

€                528 

€          11,751 

€                   - 

€          12,143 

€    136,171 

€          27,713 

€          32,026 

€    49,050 

€          13,469 

€            8,708 

€    30,247 

€                358 

€          12,518 

€    35,237* 

€            1,439 

€          26,340 

€    30,829 

€            2,353 

€          16,458 

€    35,578* 

€            8,241 

€          15,204 

Note: C27.5.1 and C29.3.1 information for total production from 2016. 

Source:  Interim  evaluation  study  calculations  based  on  Eurostat  Manufacturing  Statistics 
sbs_na_ind_r2 

69 

 
 
 
 
EU production of low voltage products, 2007-2017 

Source: Interim evaluation study calculations based on Eurostat Manufacturing Statistics sbs_na_ind_r2 

Industry composition of selected NACE categories by enterprise size, 2017 

Source:  Interim  evaluation  study  calculations  based  on  Eurostat,  Industry  by  employment  size  class 
(NACE Rev. 2, B-E) [sbs_sc_ind_r2] 

70 

050000100000150000200000250000Production (million euro)Minimum low voltage productsAdditional low voltage products0%10%20%30%40%50%60%70%80%90%100%0 to 910 to 1920 to 4950 to 249250+ 
 
  
 
 
 
 
EU trade with RoW in full (minimum and additional) category of low voltage products, 2007-2018 

Source: Interim evaluation study calculations based on Easy Comext 

EU 

low 

voltage 

trade 

(maximum 

range) 

with 

extra-EU 

partners, 

2018

Source: Interim evaluation study calculations based on Easy Comext 

71 

020000400006000080000100000120000140000200720082009201020112012201320142015201620172018Million euroImports from RoWExports to RoWTrade deficit05000100001500020000250003000035000400004500050000550006000065000ImportExportImportExportImportExportImportExportImportExportImportExportImportExportImportExportChinaUSAJapanRussiaKoreaSwitzerlandTurkeyIndiaMillion EURO 
 
 
 
 
EU trade with China in low voltage products (maximum range), 2007-2017 

Source: Interim evaluation study calculations based on Easy Comext 

EU consumption of low voltage products (maximum range), 2007-2017 

Source: Interim evaluation study calculations based on Easy Comext 

72 

0500010000150002000025000300003500040000450005000020072008200920102011201220132014201520162017Trade (million euro)EU ImportsEU ExportsTrade deficit05000010000015000020000025000020072008200920102011201220132014201520162017Million EUROConsumption 
 
 
 
 
 
 
 
 
ANNEX 5  

DESK RESEARCHESRESEARCHES 

Researches used for Interim evaluation 

Category 

Subcategory 

Title 

Author(s)/Org.  

Directives  

Legislation 

Regulations  

Directive 93/42/EEC of 14 June 1993 concerning medical devices 
Directive 2001/95/EC of the European Parliament and of the Council 
on General Product Safety 
Directive 2006/42/EC of the European Parliament and of the Council 
on machinery, and amending Directive 95/16/EC (recast) 
Directive  2009/125/EC  of  the  European  Parliament  and  of  the 
Council  establishing  a  framework  for  the  setting  of  ecodesign 
requirements for energy-related products. 
Directive  2014/35/EU  on  the  harmonisation  of  the  laws  of  the 
Member  States  relating  to  the  making  available  on  the  market  of 
electrical equipment designed for use within certain voltage limits 
Directive 2014/32/EU on Measuring Instruments 
Directive 2014/33/EU of the European Parliament and of the Council 
on  the  harmonisation  of  the  laws  of  the  Member  States  relating  to 
lifts and safety components for lifts 
Directive 2014/34/EU of the European Parliament and of the Council 
on  the  harmonisation  of  the  laws  of  the  Member  States  relating  to 
equipment  and  protective  systems  intended  for  use  in  potentially 
explosive atmospheres (recast) 
Directive 2014/53/EU of the European Parliament and of the Council 
on the harmonisation of the laws of the Member States relating to the 
making  available  on  the  market  of  radio  equipment  and  repealing 
Directive 1999/5/EC 
Regulation  (EC/EU)  N°244/2009  -  Ecodesign  requirements  for 
Lighting products  
Regulation (EU) No 801/2013 - ecodesign requirements for standby, 
off  mode  electric  power  consumption  of  electrical  and  electronic 
household and office equipment 
Regulation  (EU)  No 66/2014  -  ecodesign  requirements  for  domestic 
ovens, hobs and range hoods 
Guidance document on the low voltage Directive transition  

Manufacturers' guide for lighting products 

Blue guide' on the implementation of the EU product rules  

Guidelines 

Low Voltage Directive guidelines 

RoHS 2 FAQ  

Rules of procedure for the committee on electrical equipment 

List of ecodesign regulations for products 

Opinion: toasters, grills, roasters and similar 

Opinion: portable child-appealing luminaires  

Guidance Docs 

Opinions 

Opinion: safety of toasters 

Opinion: safety of cable reels 

Opinion: safety of cosmetic tanning devices 
Low  Voltage  Directive  (LVD)  -  Obligation  to  put  the  two  digits  of 
the year in the Declaration of Conformity 
Low  Voltage  Directive  (LVD)  -  New  declaration  of  Administrative 
Cooperation Working Group (ADCO) on child appealing appliances 
Low Voltage Directive (LVD) - Socket outlet with switch 
Low Voltage Directive (LVD) - Legal Framework for the placing on 
the market of Electric vehicles and related equipment 
Low Voltage Directive (LVD) - CE marking in cord sets 

LVD  Working 
Party Docs 

AdCo Docs 

Declaration of the LVD AdCo Group 

Final Report - cross Border Market Surveillance  

73 

EU 

EU 

EU 

EU 

EU 

EU  

EU  

EU  

EU  

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

LVD WP 

LVD WP 

LVD WP 

LVD WP 

LVD WP 

LVD AdCo  

LVD AdCo  

 
 
  
 
Final report - LVD Market Surveillance Campaign 2007  - Electrical 
Safety of Cord Extension Sets 
Recommendation regarding Child-Appealing Household Appliances   LVD AdCo  
ATLAS  to  uniformly  discriminate  between  portable  luminaries  for 
children and adults 
 Recommendation on General Issues  

LVD AdCo  

LVD AdCo  

LVD AdCo  

Recommendation Hot surfaces  

Recommendation on LED replacement tubes 
Information Sheet - Pumps and other electrical appliances for mobile 
swimming pools 
Non-functional Hot Surfaces Project  

Fusing resistors applications  

 LED and Compact Fluorescent Lamps Project 
ATLAS  to  uniformly  recognize  household  appliances  with  child 
appealing designs 
Recommendations  of  the  Administrative  Co-operation  Working 
Group 
Recommendation  on  stationary  and  portable  spas,  important  safety 
information  

Study on the implementation of the Low Voltage Directive  

Impact  Assessment  of  various  policy  options  for  a  possible 
amendment of the Low Voltage Directive  
Evaluation of the internal market legislation for industrial products 
Evaluation/Fitness  Check  Roadmap  of  the  Low  Voltage  Directive 
2014/35/EU  
Refit  evaluation  on  the  implementation  of  market  surveillance 
Regulation (EC) No 765/2008 carried 
Principle approval of Sunshower 

Sunshower Approval by IEC 60364-7-701 

Tests 
Certificates 

and 

Fire Investigation Research 

Test report 

LVD AdCo  

LVD AdCo  

LVD AdCo  

LVD AdCo  

LVD AdCo  

LVD AdCo  

LVD AdCo  

LVD AdCo  

LVD AdCo  

ERA  Technology 
Ltd 
Risk  &  Policy 
analysts Ltd 
Panteia 

EC 

EC 

NEN 

NEN 

LFB 

NFH 

Evaluation  and  
Impact 
Assessment  
Docs 

Certificate of Compliance Sunshower Pure 

Declaration of conformity 

Rules of procedure for the committee on electrical equipment 

Safeguard Notification 

CEO Sunshower 

Manufacturers' obligation to ensure conformity in series production 

BMWFM 

Rules 
Notifications 

and 

CIRCAB files 

Notification to Korea  

Relationship LVD and Metrology 

Sunshower case 

Opinion from ANEC  

Opinion from ANEC  

Opinions 

SCENIHR Preliminary Opinion  

DE Statement on SCHEER Opinion sunbeds 

BfS Statement SCHEER opinion 

EC 

EC 

EC 

ANEC 

ANEC 

SCENIHR 

DE 

BfS 

Position of Slovenia 

Vitamix position on the formal objection to Standard EN 60335-2-14   Vitamix 
Ministry 
Economic 
development  and 
technology 
FR  

France comments  

of 

MSs' comments 

UK comments 

Objection from the Federal Republic of Germany 

Formal 
objections 

United Kingdom Formal Objection  

Cyprus Formal Objection 

Communication Germany Formal Objection 

UK 

Franz Stelz 

UK 

CY 

74 

 
 
 
  
  
  
  
Meetings 

Meeting Report  

Minutes meeting on EN 60335-2-14 related to blenders 

A-deviations in CENELEC European Standards  

A-deviations Annex B 
Low  Voltage  Directive 
recommendations 
Draft guidance document on the low voltage directive transition 

-  Guidelines  on  application  and 

Guidelines 

Draft Guidelines Low Voltage Directive 

Guidelines Low Voltage Directive 

Common guidelines 
Draft  Applicability  of  the  LVD/EMCD/RED  to  Specific  Categories 
of Products 
Annex to the Guidelines for the management of the European Union 
Rapid Information System 
Avis  aux  opérateurs  relatif  à  la  classification  des  lasers  et  sources 
assimilées 
Draft decision safety requirements laser products 

CE marking in cord sets 

Regulations  

Exemption in EMCD, LVD and RED 

Several products 

Draft Exemption in EMCD , LVD  and RED 

Transitional agreements 

Draft meeting report 

Danish reply to the list of standards having A-deviations  

Situation concerning Finnish A deviations 

Comments from Norway to the list of A-deviations 

Swedish A-deviations in standards for LVD 

MSs'  comments 
on A-deviations 

United Kingdom (GB) comments to the “LVD” A-Deviations 2005 

Belgian (BE) comments to the “LVD” A-deviations 2005 

Austrian comments on A-deviations  

German (DE) comments to the “LVD” A-deviations 2005 

Irish (IE) comments to the “LVD” A-deviations 2005 

List of Swedish A-deviations 2005 

Spanish comments to the LVD  A-deviations 2005 

Swedish (SE) comments to the “LVD” A-deviations 2005 

Risks from the use of lasers on human skin  

Articles 

Special Issue Title: Apoptosis 

files 

CIRCAB 
Restricted 
documents 

Other  

Reports 
studies 

and 

The Home Appliance Industry in Europe 2017-2016 

Study: competitiveness of the electrical and electronic engineering industry 
Definition of a Research and Innovation Policy Leveraging Cloud Computing 
and IoT Combination 
What  trends  offer  opportunities  on  the  market  for  electronics  and  electrical 
engineering? (2017) 
Pulse of the European Shopper - ComScore Survey 

Global Consumer Insight Survey 2018 

Reshoring of EU Manufacturing 2014 

Literature Overview: Relocation of EU Industries 
Annual report 2016: Globalisation slowdown? Recent evidence of offshoring 
and reshoring in Europe 

75 

EC 

EC 

EC 

EC 

EP 

EC 

FR 

EC 

EC 

EC 

EC 

EC 

Safety 

EC 
Danish 
Technology 
Authority 
Safety 
Technology 
Authority 
DSB 
Head  of  product 
safety department 
GB 

BE 

AT 

DE 

IE 

SE 

ES 

on 

SE 
Commission 
Radiological 
Protection 
Journal 
of 
Carcinogenesis  & 
Mutagenesis 
APPLiA 

EC 

EC 

CBI 

UPS 

PWC 

EPRS 

EP 

ERM 

 
 
  
  
  
  
  
  
Real World Consumer Behaviour- Briefing Note 3: Consumer Behaviour and 
Electronics 
Navigating the Product Mindset (Survey) 

EcoLogic 

UL 

76 

 
 
 
 
 
 
ANNEX 6  

EVALUATION QUESTIONS 

The evaluation assesses the relevance, effectiveness, efficiency, coherence, and EU added value 
of  the  Low  Voltage  Directive.  To  this  end,  a  set  of  questions  was  defined  to  guide  the  data 
collection and analysis (see tables below), as indicated in the evaluation roadmap. 

Table 1 – Evaluation questions: effectiveness 

Topic 

Evaluation questions 

Internal market 

Health 
safety 

and 

Progress 
towards 
the 
achievement  of 
the objectives 

To what extent have the specific objectives of the LVD related to the internal market been achieved?  
What are possible shortcomings in this regard? 
Are  any  cases  of  discrepancies  detected  in  interpreting  the  requirements  of  the  LVD  by  the  Member  States  for  particular 
products? 
To what extent has the LVD contributed to an effectively operating internal market for electrical equipment in its scope?  
What are possible shortcomings in that regard? 
Are  there  any  barriers  preventing  the  effective  application  of  the  LVD  and/or  particular  situation  creating  difficulties  in 
achieving the internal market? 
To what extent have the specific objectives of the LVD related to the health and safety been achieved?  
What are possible shortcomings in this regard? 
How  effective  are  Member  States  authorities  in  identifying  non-compliant  products  and  to  what  extent  does  it  affect  the 
effectiveness of the LVD? 
To what extent has the LVD achieved its aims for the products in its scope with regard to the protection of health and safety of 
persons, domestic animals and property? 
Has the LVD enabled the introduction of such equipment on the market by guaranteeing a high degree of safety and protection 
for the health of persons, domestic animals, and properties? 
What are possible shortcomings in that regard? 
To  what  extent  can  the  progressing  towards  the  objectives  be  credited  to  the  LVD  or  do  external  factors  influence  the 
achievements? 
To  what  extent  has  the  development  and  use  of  the  European  harmonised  standards  contributed  to  the  effectiveness  of  the 
LVD? 
Are  there  any  aspects/means/actors  that  render  certain  elements  of  the  LVD  more  or  less  effective  than  other?  If  there  are, 
what lessons can be drawn from this?  
Where expectations have not been met, what obstacles hindered their achievement? 

Source: European Commission – Terms or Reference 

Table 2 – Evaluation questions: efficiency 

Topic 

Costs 
benefits 
stakeholders 

and 
for 

Efficiency 
of 
the intervention 

Evaluation questions 
What are the regulatory costs and benefits for the different stakeholders and/or other actors?  
How affordable were the costs borne by the different stakeholders? 
What does this represents in terms of administrative and reporting burdens on stakeholders and/or other actors?  
To what extent discrepancies in interpretation between Member States create burdens for economic operators? 
To what extent has the LVD been cost-effective? 
To  what  extent  have  the  costs  of  the  Directive  as  a  whole  been  justified,  and  proportionate,  given  the  benefits  that  were 
achieved? 
Could the objectives be achieved at a lower cost? 

Table 3 – Evaluation questions: relevance 

Topic 

Relevance 
objectives 

Relevance 
scope 
Relevance 
articles 

of 

of 

of 

Evaluation questions 
To what extent is the objective of ensuring a high level of safety for electrical equipment still in line with the needs at the EU 
level? 
To what extent is such objective still relevant today? 
To what extent is the objective of the functioning of the internal market still in line with the needs at the EU level? 
To what extent is this objective still relevant today? 

 Is the scope of the Directive still appropriate? 

Are the Articles of the Directive still relevant today? 

77 

 
 
 
 
 
 
 
 
Table 4 – Evaluation questions: coherence 

Evaluation questions 

To what extent is the intervention coherent internally?  

internal 
of 

Topic 
The 
coherence 
the Directive 
External 
coherence 
the Directive 

of 

To what extent are there any issues of coherence with other legislations with similar objectives? 
Are there overlaps or complementarities between the Low Voltage Directive and any other EU legislations? 
To what extent is the intervention coherent with wider EU policy? 

Table 5 – Evaluation questions: EU added-value 

value 
to 
level 

Topic 
Added 
compared 
national 
action 
Added  value  to 
stakeholders 

Evaluation questions 

What is the additional value resulting from the Directive, compared to what could be achieved at national/regional level? 

What is the added value of the Directive for stakeholders? 

78