Lets go a little deeper into the low voltage directive. The directive is limited to products with a voltage of 50 and 1000 Vac and for DC between 75 and 1500 V. The majority of the lighting products therefore need to comply with this directive however I do get manufacturers that produce equipment like LED modules that have a lower voltage and therefore they claim that they do not need to comply,
Basically they are right. A led module that is connected to a 50 Vdc supply does not need to be CE marked based on the low voltage directive. The module does not need to comply with the standard for LED modules (EN 62031). But there is a small problem. If the module is used in a luminaire, it is connected to a driver and this driver is most probably connected to a voltage that is with the limits of the low voltage directive. This means that this luminaire needs to comply and that in it self results in the fact that the module needs to comply with the respective standard.
In the end this means that the module needs to comply and if the module manufacturer did not take care of this compliance the luminaire manufacturer might be in for a surprise. He than needs to take care of the safety of the module that he buys as well.
Does this mean that the module must be completely safe in the component stage. No it does not. The module manufacturer may rely on the luminaire manufacturer to take measures to assure compliance with for example insulation requirements with regard to touch safety. For example, if you have a chip on board (COB) module it will rely for the electrical safety on the measures taken in the luminaire. This also means that the product can not be CE marked based on this directive.
This is also true for the photo biological safety of modules. It is possible to argue that these modules do not need to comply (note that the GPSD directive is applicable and requires compliance). Also here it should be clear that when these modules are being used in a luminaire the manufacturer of the luminaire will need to comply. If the module manufacturer did not take care of this the luminaire manufacturer will have to take care of this. Generally this causes additional testing costs that could have been avoided.
There are more components that are used in luminaires. The majority of them need to be CE marked also on the basis of this directive. For example Electronic control gear, when falling in the voltage limits, needs to comply and needs to be CE marked. For those components that are not encased again the rules as above are applicable and CE marking can not be used. An example is a driver that is supplied as PCB with components only. All touch safety needs to be complied with through measures in the luminaire. A risk analysis can not be made and than CE marking according to this directive is mot possible. Also in this case the manufacturer still needs to take into account all measures required other than touch safety.
For more information you can also read the Guidelines on the application of the directive 2006/95/EC.