Few common questions about the Low Voltage Directive

An EU Directive is a legislative act of the European Union that requires Member States to achieve a result without dictating the means of achieving that result. Directives generally leave Member States a certain degree of freedom as to the precise rules to be adopted. Directives may be adopted by different legislative procedures, depending on their subject matter.

Harmonized standard is a European standard that is developed at the request of the European Commission for application in harmonized legislation of the European Union. Harmonized standards are developed by recognized European standardization organizations CEN, CENELEC or ETSI. Manufacturers, other economic operators or conformity assessment bodies can use harmonized standards to demonstrate that products, services or processes comply with relevant EU legislation. Harmonized standards must be published in the Official Journal of the European Union (OJEU).

Standards are voluntary, consensus-based, and do not impose any regulations as such. They provide specifications for tests and test methods (interoperability, safety, quality, etc.).

However, laws and regulations may refer to standards and even make their application mandatory. In the European Union, EU directives, regulations, and other regulatory documents may refer to European standards. This is the case within the framework of the “New Approach”, where European standards are used to provide a presumption of conformity with the “essential requirements” of directives. “Essential requirements” are mandatory. Manufacturers always have the freedom to choose any technical solution that ensures compliance with the essential requirements of directives. This is a very important clause as it guarantees the basis for technical development, which is crucial when manufacturers of new or innovative products for which there are no standards yet want to certify their products in accordance with the European legal framework. The same principle applies to the application of national technical regulations that have transposed European New Approach directives.

While the LVD Directive primarily focuses on safety aspects, the mandatory documentation required for compliance encompasses a broader scope than just safety. The documentation should include all necessary information for the safe use of the product, enabling consumers to properly assemble, install, operate, store, maintain, repair, and dispose of the product. The manufacturer is responsible for determining the relevant information to be included in the instructions and safety information for each specific product. A single document can contain both safety information and instructions.

The European Commission requires CENELEC to deliver a list of harmonized standards two months before the new directive enters into force. If the list of harmonized standards related to the new directive is not published in a timely manner, Article 27 of the new directive states that references to the previous directive will be interpreted as references to the new directive.

This provision serves to ensure a smooth transition between the old and new directives, preventing regulatory gaps and potential disruptions to product compliance. In the absence of an updated list of harmonized standards, manufacturers can continue to rely on the standards from the previous directive, assuming they are still relevant and applicable to the products under consideration.

The Rulebook on Electrical Equipment Intended for Use Within Certain Voltage Limits (“Official Gazette of the Republic of Serbia”, No. 25/16 and 21/20) is applicable in the Republic of Serbia. This rulebook is harmonized with all the principles and essential requirements of Directive 2014/35/EU of the European Parliament and of the Council of 26 February 2014 on the harmonization of the laws of the Member States relating to electrical equipment designed for use within certain voltage limits, which has been applied in the European Union since 20 April 2016.

According to Article 3 of the Regulation, it applies to electrical equipment intended for use within voltage limits of between 50 V and 1 000 V for alternating current and between 75 V and 1 500 V for direct current.

It covers a wide range of electrical equipment for consumers and professional users, such as: household appliances, cables, power supplies, laser equipment, individual components, fuses, etc.

The document of conformity is a document that confirms that a product is in compliance with the requirements of a technical regulation. These requirements can vary, but they most commonly concern safety and other technical aspects.

The document of conformity is the outcome of a completed conformity assessment procedure. There are different types of document of conformitys, such as: certificate, declaration of conformity, test report, inspection report, or other document that confirms the product's compliance with the prescribed requirements (Law on Technical Requirements for Products and Conformity Assessment – „Official Gazette of the Republic of Serbia“, No. 49/21 and Regulation on the Manner of Conducting Conformity Assessment and Issuing Certificates of Conformity – „Official Gazette of the Republic of Serbia“, No. 127/21). The technical regulation prescribes the type of document of conformity required for a specific product or group of products.

The Declaration of Conformity (DoC) is one of the most important documents for a large number of products that are placed on the market or put into use in the Republic of Serbia. This is particularly the case for electrical equipment, electromagnetic compatibility, machinery, lifts, personal protective equipment, and others.

The Declaration of Conformity is a mandatory „output“ document for products placed on the market or put into use. This document represents a kind of legal statement by which the manufacturer or its representative confirms: that all relevant requirements of the technical regulation have been met; that it possesses technical documentation, or other documentation on testing, which undoubtedly confirms the fulfillment of the requirements of the technical regulation, as well as that it takes responsibility for the product's compliance with the prescribed requirements, or for product safety.

It is a rule that the Declaration of Conformity for a product, regardless of whether it is a domestic product or an imported product, must always refer to the Serbian technical regulation that prescribes the essential requirements for that product.

The Certificate of Conformity (CoC) is a new, specific type of conformity document that confirms the compliance of a particular product with the relevant requirements of a technical regulation and which is not characteristic of all technical regulations. This document was introduced into Serbian technical legislation through three rulebooks: the Rulebook on Electrical Equipment Intended for Use Within Defined Voltage Limits, the Rulebook on Electromagnetic Compatibility, and the Rulebook on Machine Safety („Official Gazette of the Republic of Serbia“, No. 13/10).

These regulations prescribe the obligation to issue a Certificate of Conformity for electrical and electronic devices and appliances intended for use within voltage limits of between 50 and 1000 V for alternating current, as well as 75 and 1000 V for direct current, and for electromagnetic compatibility of devices.

The Certificate of Conformity is drawn up or issued by the conformity assessment body appointed by the Minister responsible for economic affairs (notified body). All notified conformity assessment bodies are listed in the Register of Notified Bodies, which is kept in electronic form at the Ministry responsible for economy. The address of the website where this register can be searched is: https://tehnis.privreda.gov.rs/en.html.

Product conformity with the essential requirements of Serbian technical regulations is indicated by placing the Serbian Mark of Conformity to the product.

The Serbian Mark of Conformity is the only mark that confirms that a product placed on the market or put into use in the Republic of Serbia is in compliance with the requirements of the Serbian technical regulation, if its placing is provided for by that regulation. 

The shape, appearance, and content of the Serbian Mark of Conformity are prescribed by the Regulation on the Conformity Mark ("Official Gazette of the Republic of Serbia", No. 04/22).