Hello Experts,

I am looking for help puzzling through a question - thinking in the context of 
large industrial machines - a total machine product that operates from 
LVD-voltages is out of scope of the LVD per se, but I am wondering about the 
LVD-voltage components.

I am confident/certain the LVD-voltage components (e.g. circuit breakers, 
controllers, lighting) that enter the EU as a component of the machinery do not 
need to be CE marked for the LVD because, in that scenario, they are not 
products placed separately on the EU market.

However, I am less confident about replacement parts for those same LVD-voltage 
components - they will be placed separately on the EU market. However, they are 
placed not for 'general' sale to the public, but with the intention of 
becoming, in effect, the component of a machine. My current thinking is that 
these components also do not need to be CE marked for the LVD, but it might 
smooth Custom's clearance if they travel with a notice indicating they are 
replacement parts and not for 'general' sale.

Does this seem to be sound logic?

Best Regards,
-Lauren


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