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My company is planning to produce a fork sensor (example). Before starting design, I looked up EU Directives to find if there are any electrical requirements for product safety. First stop was Low Voltage Directive, however it clearly states that products between 75V DC and 1500 V DC are in the scope of the directive.

However, there also is a harmonised standard under LVD which fits for the definition of my product: EN 60947-5-2.

My understanding is that, LVD only cares about product safety, and wants to ensure that nobody gets hurt while device is in operation. The harmonised standard more specifically defines what the product should behave, however not obeying it is not a problem for the product to be in the European Trade Zone.

My questions are:

  1. Does a product operating below 75 Volts mean that it is intristically safe (per European Standards)?
  2. Is compliance to RoHS and EMC directives enough to mark my product with CE?
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  • \$\begingroup\$ CE is a minefield, but the fast answer is no. The safety directive must be met (even if your product does not at first glance seem to be within scope), and there is the interesting one of foreseeable misuse. My advice is to ask an expert (people spend years in this area before they are fully competent). \$\endgroup\$ – Peter Smith Feb 10 '19 at 12:44
  • \$\begingroup\$ @2. No, it's a good start, but you need e.g. product documentation (technical dossier) etc. Do check europa.eu/youreurope/business/product/ce-mark/index_en.htm \$\endgroup\$ – Huisman Feb 10 '19 at 12:44
  • \$\begingroup\$ @1 No. E.g. I can make a fire with products operating below 24V. Your sensor might e.g. catch fire or explode (when misused). Your product however does not need to comply to the "Directive 2014/35/EU on Low Voltage" as it is excluded by Article 1 of said directive. \$\endgroup\$ – Huisman Feb 10 '19 at 13:05
  • \$\begingroup\$ @Huisman do electrical products below 75VDC have a specific test standard? \$\endgroup\$ – C K Feb 12 '19 at 6:59
  • \$\begingroup\$ How could they? Almost all electrical products behave differently. I would suggest looking at competitors products and try to copy what approvals they have listed for their device. \$\endgroup\$ – MrGerber Feb 13 '19 at 12:50
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My understanding is that, LVD only cares about product safety, and wants to ensure that nobody gets hurt while device is in operation.

Pretty much, yes. It cares about electrical safety, such as preventing humans from direct contact with voltage sources, as well as suitability of materials in regards to fire hazards etc.

LVD does not care about functional safety, such as the application consequences if a switch isn't working correctly. Nor does it care about safety components. That's the Machinery directive. The EN 60947 standards are harmonized below LVD and Machinery directives both.

I would also imagine that shock/vibration requirements apply to the type of product you linked.

Does a product operating below 75 Volts mean that it is intristically safe (per European Standards)?

Not at all, it simply means that the LVD directive does not apply. You still have various application-specific directives though, depending on the nature of the application.

Also notable, if the product contains any form of radio, the RED directive kicks in with a weird rule that, in addition to radio compliance, also enforces LVD directive compliance regardless of supply voltage used.

Is compliance to RoHS and EMC directives enough to mark my product with CE?

Yes, if it has <50VAC or <75VDC supply, no radio and no application-specific directives apply.

For industrial electronics, the EMC directive will point at EN 61000-6-2.

In addition, you need to address the WEEE directive on an organization level, regarding recycling of the product. That part does not need to be in the CE declaration of conformity though.

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You are correct when you state that it is about product safety during normal operation, but it is also about safety when things go wrong. For example, it should not catch fire if there is a short circuit, or the circuit is zapped with ESD.

CE marking is not a walk in the park, and because you have not found a specific norm, it doesn't mean that you don't have to apply any. You can spend days researching what norms to apply, but you will still not be 100% certain of what you need.

In my experience, the best thing is to approach one or more testing houses with the details of your design, and ask them for a quote. They will list you all the norms that apply to your design, and you will also get the contacts for when you will need to certify the board. Might as well do it early, so that you don't get a surprise later.

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    \$\begingroup\$ The use of standards is voluntary - you are not obliged to use them. You can also opt for other technical solutions to fulfil the essential requirements set out in the relevant EU directive. source: link posted in previous comment. You have to fullfil the directive, not the standard/norm. However, using norms/standards is likely the best/"easiest" way to prove you fullfilled the directive. \$\endgroup\$ – Huisman Feb 10 '19 at 18:23
  • \$\begingroup\$ I do agree asking experts/testing houses is a very decent way to go. But do explore as well for yourself. Because, you don't need to pay for advise you already found/implemented yourself... \$\endgroup\$ – Huisman Feb 10 '19 at 18:25
  • \$\begingroup\$ That is correct @Huisman, CE marking is a self certification, and all you need is to prove that have exercised due diligence to making sure that the product is safe. There is no rule that states that you have to go through a certifying body, but they are there just because it is not an easy task. It was recommended to me by a sales rep of a certifying body (in secrecy) to go to them for a quote to get the list of directives you need to comply to, even if you don't intend to use them. In the end, you end up using them anyhow, because when it come to measuring EMI you need costly equipment. \$\endgroup\$ – Elmesito Feb 10 '19 at 21:16
  • \$\begingroup\$ I have to disagree: CE marking is only allowed to be done by the manufacturer himself if the product is of low risk. Otherwise, notified bodies should be involved doing (part) of the certification. (e.g. medical equipment). The directive will clarify whether self certification is allowed. \$\endgroup\$ – Huisman Feb 10 '19 at 21:38
  • \$\begingroup\$ You are confusing CE marking with medical certifications. Those are two different things. To place a CE Mark on electrical products to be legally sold on the European Market, a manufacturer has to be able to demonstrate compliance with the applicable EU regulations and directives. This does not require external bodies of you have the capabilities in house. However, in addition to the CE marking, medical devices also require a ISO13485 certification, which is another can of worms, which requires independent external certifying bodies. \$\endgroup\$ – Elmesito Feb 10 '19 at 21:55

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