1 January became EC Directive day. Following the earlier introduction of the Machinery Directive and last year’s EMC Directive, the 1 January 1997 now sees CE marking become mandatory for the Low Voltage Directive.
As a consequence, only those items of electrical equipment that satisfy the CE marking requirements of the LVD will be entitled to free circulation throughout the European Economic Area. Electrical and electronic equipment manufacturers are faced with the danger of non-compliant goods being excluded from the marketplace.
Although the LVD has been in existence for over 20 years, in reality the modified LVD brings with it a number of fundamental differences compared to its earlier version that could prove dangerous if ignored.
Although the technical requirements of the LVD remain largely the same, in its new form demonstrating compliance takes on even greater importance. The modified version also recognises the validity of self-certification by manufacturers themselves. There is no requirement for equipment to be tested or marked for approval by an independent third party.
Given these differences, the real danger exists that manufacturers will fail to realise their new responsibilities for documentation and declarations of conformity with the LVD.
Many responsible manufacturers will have undoubtedly implemented safety testing procedures in keeping with the original 1973 LVD. However, the key to successful compliance with the LVD, as amended by the 1993 CE marking Directive will be keeping formal test records, the associated technical documentation and declaration of conformity as a means of demonstrating due diligence.
In particular, many manufacturers may find that test routines, procedures and equipment previously acceptable under the legislation may not be sufficient to prove compliance with the Directive in its updated form.
As the first point in the supply chain, it is the responsibility of manufacturers based within the EEA to demonstrate compliance with the LVD. For products imported into Europe, this duty falls upon the chosen European representative or the first importer into the market.
Before a product enters the market, the manufacturer must establish the technical documentation to allow assessment of the conformity of the electrical equipment with the requirements of the Directive. As part of the technical documentation, maintaining effective test results and reports is a vital requirement of the LVD and will form part of the defence in the event of a challenge.
Once a satisfactory documentation file is produced, the manufacturer must then establish a written declaration of conformity to allow the CE mark to be applied. The declaration of conformity is an important element both for assessment of the conformity of the electrical equipment and for the market surveillance procedure.
– Rod Taylor, managing director, Seaward Electronics, Peterlee, County Durham