In the new Low Voltage Directive 2014/35/EU every marketparticipant has his own definition.

  • The manufacturer is the one who manufactures electrical equipment and sells this under his name or trademark.
  • The Authorized representative is the person who is authorized by a manufacturer.
  • The importer is a European-based natural or legal person who places electrical equipment from a third country in Europe on the market.
  • The distributor is a natural or legal person who brings electrical equipment from different manufacturers or importers on the European market.

The new Low Voltage Directive states that the manufacturer should conduct an internal production control for his product, in which he ensures and declares that his product complies to the applicable requirements of the new Low Voltage Directive 2014/35 / EU. Furthermore, the manufacturer has to compile the technical documentation for his product, from which the risk analysis and assessment are an important component. Likewise, the manufacturer ensures that the manufacturing process and its monitoring meet the requirements of the new Low Voltage Directive. The manufacturer shall affix the CE mark on its product and draw EU declaration of conformity. The requirements for compliling a conformity assessment are held exclusively by the manufacturer and a notified body is not needed for the conformity assessment procedures.

The new Low Voltage Directive 2014/35 / EU also proposes that the importer has to verify that the electrical equipment, which he wishes to place on the market, complies with the requirements of the new Low Voltage Directive. The importer must also ensure that conformity assessment procedures have been performed, the CE mark is affixed on the product and the technical documentation is available. The importer must affix this name and address on the product and if the product is too small on the product packaging. The distributor and importer must be prepared to cooperate actively in order to provide the government all necessary information about the electrical equipment. Operators are required to keep the identity of all other market operators, however updated versions are not compulsory.

If any of the operators of the electrical equipment sell the product under their own name or trademark or apply such changes to the electrical equipment that the conformity of the Directive no longer applies, then he is seen as the manufacturer.
Governments should facilitate communication between traders, market surveillance authorities and consumers by encouraging operators to mention a web address in addition to their postal address.

The new Low Voltage Directive 2014/35 / EU will come into force on April 26, 2016. For questions please contact us via +31 (0) 294 48 33 55 or via Our technical legal experts are always willing to help.

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