Common LVD, RED, and EMC Compliance & Recall Risks for Electrical Products Sold in the EU & UK [Research]

Sofeast commissioned some research recently on which electrical products being imported into the EU fell foul of the LVD, RED, and EMC regulations over a recent 6-month period, what the issues were, and what actions were taken by market surveillance authorities.

By seeing the issues, you will get an insight into what market surveillance authorities are looking for so you can ensure your manufacturers focus on not making the same mistakes.

What are the key applicable regulations & directives?

In general, we investigated these common regulations and standards that market surveillance authorities tend to check products against:

• LVD
  The Low Voltage Directive (LVD) is an EU regulation put in place to ensure that electrical equipment between certain voltages (50-1000 AC and 75-1500 DC) imported into the EU reaches certain safety requirements, such as reducing the risk of fires, shocks, chemical problems, and more.
  We explain the Low Voltage Directive in this video:

• RED
  The Radio Equipment Directive (RED) governs radio equipment safety, ensuring that products imported into the EU are safe, use permitted RF signals, and don’t interfere with other devices.
• EMC
  The Electromagnetic Compatibility (EMC) Directive is there to ensure that electrical and electronic products brought inot the EU do not emit an unauthorized level of electromagnetic interference that could affect other products and that they are in turn unaffected by it themselves.
  We go through RED and EMC in this video:
  
  

Incidents occurring in electrical products

During 6 months in 2023 (April to October), we found that there were around 180 cases where electronic products didn’t comply with LVD, RED, or EMC.

Countries of origin

The countries of origin were varied and not only the PRC was responsible for manufacturing the products, although 142 cases were from China. Many incidents were recorded in products from other European and Asian countries, too:

• Czechia 1
• Italy 2
• People’s Republic of China 142
• Poland 3
• Portugal 1
• Spain 1
• Taiwan 1
• The Netherlands 1
• Türkiye 2
• United Kingdom 1
• Unknown 25
• Vietnam 1
  Grand Total 181

What types of products were found to be problematic?

There were actually 75 different kinds of electronic products flagged by the authorities. The top 12 that didn’t comply with LVD were:

1. USB chargers (28 incidents)
2. Lighting chains (16)
3. Extension leads (11)
4. Travel adaptors (9)
5. Hair dryers (9)
6. Air humidifiers (9)
7. Soldering iron (3)
8. Portable power station (3)
9. Multiplug socket (3)
10. Hot plate (3)
11. Cord extension set (3)
12. Aroma diffuser (3)

The product type that didn’t comply with RED was:

• Lamp holders (4)

Nature of the non-compliance

The vast majority of products caught by market surveillance authorities did not comply with LVD and a few were also found in breach of RED. In this period, we didn’t find any reports of EMC issues.

Not complying with LVD is a problem, not only from a market-access point of view, but also because the products could be a risk of fire, electric shock, or other harm such as releasing chemicals. Importers could very easily find themselves in legal trouble if a non-compliant product later caused a user to be injured.

Although only a few products didn’t comply with RED, let’s look at why that’s an issue. First, the products could interfere with other products leading to disruption of, for example, radio equipment. In addition, these products could also be a risk of malfunction, shock, or even exposure to unsafe levels of radiation.

Which countries reported the most issues?

Hungary (by far), Lithuania, Estonia, and Germany reported the most cases of LVD breaches, and The Netherlands was responsible for reporting products that didn’t comply with RED. If you import into the countries in the graph below this can give you some idea about how zealous they are in enforcing these regulations.

What steps did the authorities take?

There were a number of different actions taken by different countries:

The most common was to recall the product from end users, followed by demanding that the product be completely withdrawn from the market. The actions depend on different factors, such as how serious a hazard the product was deemed to be, however, you will note that all actions taken involve the products no longer being sold because non-compliance with LVD and RED means that products cannot legally be sold in the EU.

General advice to reduce such risks

Make sure you work with suppliers who are aware of the LVD, EMC, and RED regulations. Perhaps they can show you compliant products that they made in the past and you should be able to get a feel for if they truly understand the regulation when you speak with them.

There are a number of requirements. Some of them are listed in the text (available for free on the EU Commission’s website) of those directives. Others are in the technical standards relevant to your product. It can get complex, but make sure you identify and address risks. 

Even if your supplier runs their own lab tests and provides you with a report, unless they’re proven to be capable and trustworthy beyond doubt it’s advisable for you to run your own laboratory tests, at least initially.