Recently A discussion came up. If a product is being sold that complies with all requirements and then it is possible to buy an accessory for that product as well, should that be evaluated. In the case that we were discussing a luminaire for recessed mounting could be supplied with a special box so that it would be changed into a luminaire for building up.
The luminaire itself was safe but than an accessory is sold especially designed to basically construct a new luminaire. Of course the final assembly is the responsibility of the electrician that will assemble the accessory to the fixture. However the electrician must be able to do this in the right way and therefore the construction must be made in a way so that end product will be safe as well.
This means that the correct components should be supplied. For example the driver must fit is the appropriate place and you should be providing the right components to fit this driver. Also there must be a clear instruction on how to do that. More simple said it should be made in a way that no mistakes can be made. So keep it simple but very clear.
It this specific case there was space for the driver made and there was no need for a special component to fit it. That is a good solution. However the luminaire was a class III product and now became in one instance a class I product. This means in this specific case that an earthing connection needed to be made to the luminaire. There are some more complications like the correct connection terminals should be used and they should be made in a way that they can be fixed in the box, or you need to use special connection blocks for that. These parts should be supplied as well.
The change looked so easy but when holding the standard against the whole construction it became clear that there where a lot more issues to be dealt with. Sure this was all possible and not very complex but the message I want to give is that when supplying a accessory check again if the assembled product does comply with the essential requirements from the directives that apply. Be clear and thorough in the instructions and provide all components needed to make it a safe and compliant product.
A possibility is to let somebody make the modification according to the instructions and then check if it is as you intended it to be. If it is not rethink the instructions. If it is check if the safety requirements are still met.
You can not expect an electrician to know these luminaire constructional issue’s. Of course there will be enough electricians who would do it in the right way but this is not part of there training so it should be provided by the luminaire manufacturer. The product should be made in such a way that it is almost impossible to make a mistake during installation.