Machine Directive has high priority than Low Voltage Directive

Question

One of my colleague told me that according to European Law, manufacturers are not allowed to release products under two similar directives such as Low Voltage Directive and Machinery Directive. Products such as servo drive with integrated safety functionality are subject to Machinery Directive as a result of their safety functionality and subject to Low Voltage Directive as a result of electrical safety. As Machinery Directive also covers electrical safety, it is not allowed to declare products with functional safety according to Low Voltage Directive.

But I failed to find my colleague's assertion from CE Blue Guide.

My question is where my colleague's assertion comes from. Is low voltage directive always covered by machinery directive?

Answer 1

They are not really overlapping so you need to conform with both, assuming a supply of >50VAC or >75VDC.

The machinery directive addresses things like functional safety, operator hazards, emergency stops etc. The LVD directive addresses electrical safety. While one may argue that electrical safety is a sub category of general safety, the machinery directive does not place detailed requirements regarding such, which LVD does through harmonized standards such as for example EN 62368-1. LVD also covers things like flammable plastics and fire hazards.

On the other hand, the machinery directive has system level safety standards like EN 60204-1 (Electrical equipment of machines) which aren't present under LVD.

I'd have a hard time arguing against not claiming compliance against both directives. In fact I think I even tried that at one point (skipping LVD) but the assessor insisted that I needed both.

There are however some related directives:

• If you have wireless electronics in the product, then the RED directive applies and then also the LVD directive, no matter supply voltage. But the EMC directive does not apply (covered by RED).
• If you don't have wireless electronics, then the EMC directive applies and the LVD directive only applies in case of the mentioned >50VAC or >75VDC supply.

Answer 2

The MD refers to the LVD in Annex I 1.5.1. That's why so people believe that the MD has a higher priority. However, the MD also excludes some products in favor of the LVD in the scope. For example: household appliances intended for domestic use, ordinary office machinery, electric motors. This borderline is sometimes very unclear. And the LVD addresses more than just electrical safety in Annex I point 3 (mechanical hazards). All in all, the MD and the LVD are both safety oriented directives which could (and should?) be integrated into one product safety directive. Why this hasn't been done by the EU is unknown and unclear for me.