If/how to apply LVD (Low Voltage Directive) in this case

J

jenlianne146

#1
Hi There,

I am a CE newbie looking for some help. I work for a company that manufactures massage/chiropractor/medical tables, and in the past they have used the MDD to certify their products.

We now have a new product that is a nail "desk" (essentially a table that will be in nail salons used for manicures). It has some colored LED lights and a work lamp attached to it - these are both plugged into a power strip that plugs into the wall. The components are all individually CE certified.

My question is, does the Low Voltage Directive apply to this type of product? Or would it be only the General Product Safety Directive?

I'm assuming part of this will be somehow certifying that all the electrical components are safe when connected together, but is there also a standard that will require the desk itself has no safety issues?

I appreciate any help you can provide! Thank you!
 
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Ronen E

Problem Solver
Staff member
Moderator
#3
Re: If/how to apply LVD in this case?

Hello and welcome to The Cove :bigwave:

Why do you think that the LVD doesn't apply?

Article 1
For the purposes of this Directive, ‘electrical equipment’ means any equipment designed for use with a voltage rating of between 50 and 1 000 V for alternating current and between 75 and 1 500 V for direct current, other than the equipment and phenomena listed in Annex II.
ANNEX II
Equipment and Phenomena outside the Scope of this Directive
Electrical equipment for use in an explosive atmosphere
Electrical equipment for radiology and medical purposes
Electrical parts for goods and passenger lifts
Electricity meters
Plugs and socket outlets for domestic use
Electric fence controllers
Radio-electrical interference
Specialised electrical equipment, for use on ships, aircraft or railways, which complies with the safety provisions drawn up
by international bodies in which the Member States participate.
The current LVD is in force until 20 April 2016 (a recast was approved in 2014).
 

CharlieUK

Quite Involved in Discussions
#4
Re: If/how to apply LVD in this case?

A few word of caution

The components are all individually CE certified.

Unfortunately, there is no such thing.. Items may be CE marked, but that is a Declaration by the manufacturer, that is all.
There are plenty of non-compliant products that have CE marks on them - weekly reports of market surveillance available http://ec.europa.eu/consumers/safety/rapex/alerts/main/index.cfm?event=main.listNotifications

As a minimum, I would recommend that you:
- obtain copies of the Declarations of Conformity for any 3rd party items you integrated into your product.
- where possible, source items that have 3rd party approvals marks (UL, TUV, VDE, Nemko, CSA etc.) AND verify on the certification bodies website that the mark is valid
- have someone competent perform an evaluation of a sample of the product

By way of example, I recently broke open a CE marked mains-USB charger and found that internal clearances were < 1mm and not >4mm as required by the standard

Charlie
 
J

jenlianne146

#5
Thanks for your responses.

Follow up question - so if a component (for example, LED lighting) has a CE mark, and the declaration of conformity says it is conforming to a certain directive and standard, do I ALSO have to do the testing to confirm that it conforms before I can include it on my product that I'm trying to CE mark?

If I have a component that is NOT CE marked that I want to use, is that even possible? Even if it is UL listed?

Overall, I'm still unsure if I need to use the standards specified for each individual component, or if there is a more general standard that will help me with verifying that the product is safe when everything is connected together. (For example, for UL certification we use UL 962 for commercial furnishings. But I don't see any kind of equivalent for EU standards.)

Thanks so much!! I am really struggling! :nopity:
 

Ronen E

Problem Solver
Staff member
Moderator
#6
Hi,

I'm not an expert on general electrical equipment, but I'd like to comment from the EC regulation perspective:

Follow up question - so if a component (for example, LED lighting) has a CE mark, and the declaration of conformity says it is conforming to a certain directive and standard, do I ALSO have to do the testing to confirm that it conforms before I can include it on my product that I'm trying to CE mark?
As Charlie has pointed out, your approach can be tiered. I would say that the level of scrutiny could be based on risk evaluation (not all components have the same criticality).

1. For low risk, a CE mark with a copy of the DoC from the component manufacturer might suffice. It's not much but is better than nothing.

2. Next risk level up (or when components are not CE marked), have reputable / accreditted 3rd party certifications on file and verify their validity.

3. For high risk / when no 3rd party certification is available (and you still want to use that specific component), test / inspect.

Above all that, I assume you conduct your own testing to ensure that your finished product functions properly and meets applicable requirements. This would provide an additional assurance level (albeit at system level, not component, thus less "sensitive").

If I have a component that is NOT CE marked that I want to use, is that even possible? Even if it is UL listed?
I'm not aware of a generic requirement to use only CE marked components. It is your responsibility to ensure that your finished product is compliant and safe. If you're using non-CE-marked components you have to account for that somehow (you actually have to account for the components you use anyway, to a certain extent, even if they're CE marked).

Cheers,
Ronen.
 

CharlieUK

Quite Involved in Discussions
#7
If I have a component that is NOT CE marked that I want to use, is that even possible? Even if it is UL listed?

Assuming you are using it within stated parameters, that can be better than having it CE marked. A UL listed/recognised product is subject to factory inspections and some checks to ensure ongoing compliance.
You can check that UL mark is current at http://database.ul.com/cgi-bin/XYV/template/LISEXT/1FRAME/index.htm

Charlie
 
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