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EUProduct guide

# CE Marking for UPS and Inverters

UPS manufacturers face a dual compliance burden: CE marking under LVD and EMC, plus mandatory Ecodesign efficiency tiers that tightened significantly in July 2023. A UPS that passed Tier 1 efficiency at 25% load may not meet Tier 2 requirements — and Ecodesign non-compliance is a market access prohibition, not just a fine.

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At a glance

Applicable legislation

3

UPS topology modes

3

Key IEC/EN standards

6

## Applicable legislation

LVD

### Low Voltage Directive 2014/35/EU

All mains-connected UPS and inverter products. The primary safety standard is IEC/EN 62040-1 (safety requirements for UPS). For general power inverters, IEC/EN 62477-1 applies.

EMC

### EMC Directive 2014/30/EU

UPS and inverters generate significant harmonic and switching noise. IEC/EN 62040-2 covers EMC requirements specifically for UPS, with both conducted emission limits and immunity requirements.

Ecodesign

### Ecodesign Regulation (EU) 2019/1782

Applies to UPS products from 0.25 kVA to 10 MVA (some exclusions). Efficiency tiers (Tier 1 since January 2020, Tier 2 since July 2023) set minimum conversion efficiency at defined load points. Non-compliant UPS cannot be placed on the EU market.

## UPS conversion topologies and Ecodesign relevance

VFI (Voltage and Frequency Independent)(Double conversion / online UPS)

Load is always powered from the inverter; mains continuously charges the battery through a rectifier. Highest protection; highest conversion losses. Efficiency at partial load is the key Ecodesign test point.

VI (Voltage Independent)(Line interactive UPS)

Inverter only activates on mains failure; voltage is regulated via auto-transformer on mains. More efficient at full load than VFI. Good fit for IT equipment.

VFD (Voltage and Frequency Dependent)(Standby / offline UPS)

Load is normally powered directly from mains; inverter only activates on mains failure. Simplest and most efficient in normal operation. Limited power conditioning.

## Key harmonised standards

IEC/EN 62040-1

Uninterruptible power systems (UPS) — safety requirements

IEC/EN 62040-2

Uninterruptible power systems (UPS) — electromagnetic compatibility (EMC) requirements

IEC/EN 62040-3

Uninterruptible power systems (UPS) — method of specifying the performance and test requirements

IEC/EN 62477-1

Safety requirements for power electronic converter systems and equipment — part 1 (for inverters)

EN 61000-3-12

Electromagnetic compatibility — limits for harmonic currents > 16A per phase input (three-phase UPS)

EN 61000-3-2

Electromagnetic compatibility — limits for harmonic currents ≤ 16A per phase input (single-phase UPS)

## Frequently asked questions

### Does Ecodesign Regulation (EU) 2019/1782 cover all UPS products?

The regulation covers most UPS products from 0.25 kVA to 10 MVA with rated output voltage below 1500V AC. Certain exclusions apply: UPS integrated into other products and not separately placed on the market, UPS for use in safety-critical applications, and equipment intended for use in potentially explosive atmospheres. Verify whether your specific UPS falls within scope by checking the product category definitions in the regulation.

### Do solar inverters fall under CE marking for UPS and inverters?

Solar grid-tie inverters fall under CE marking requirements — primarily LVD and EMC — but are covered by different Ecodesign regulations (EU 2016/631 for inverters used in connection with PV systems). Solar inverters are not covered by (EU) 2019/1782 which specifically targets UPS. Stand-alone inverters for off-grid systems and battery storage inverters have their own compliance pathways. The inverter technology overlaps significantly, but regulatory scope varies by application.

### What battery safety requirements apply to UPS?

VRLA (valve-regulated lead-acid) batteries and lithium-ion batteries used in UPS have separate safety requirements. Lead-acid batteries in UPS enclosures must meet ventilation requirements to manage hydrogen gas release. Lithium-ion UPS batteries are increasingly subject to UN 38.3 transport testing, IEC 62619 (safety requirements for secondary lithium cells and batteries for stationary applications), and EU Battery Regulation 2023/1542 for battery-specific requirements.

### Is a UPS considered a machine or an electronic product for CE marking?

A standard UPS is an electronic product — it falls under LVD and EMC, not the Machinery Directive. However, a UPS integrated into a larger machine as part of the machine's power supply infrastructure is assessed as part of the machine under Machinery Directive requirements. The boundary condition is whether the UPS is placed on the market as an independent product or forms an integral part of a machine not separately placed on the market.

**Disclaimer:** Educational resource only. Ecodesign efficiency tier requirements under (EU) 2019/1782 are time-bound — always verify which tier applies to your specific UPS topology and power range before market placement.

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