Low Profile Low Voltage Junction Box
Low voltage wiring and safety - Fine Homebuilding
wiring - Do low voltage wires need to go in a junction box - Home Improvement Stack Exchange
I want to bury low voltage LED wires in the wall that have a lot of splices. Do I need junction boxes?
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I replaced some existing under cabinet lights with new LED strips. The previous installer had just left 12V wire nuts loose under the cabinet so I’m looking to tidy it up and put the new wago connections in a slim junction box I can mount under the cabinet so they aren’t visible (thinking maybe 1” thick max).
It is not required, but it can be a good idea. Personally, I would prefer them to be in conduit (e.g. ENT/smurf tube) with splices in junction boxes. Just like with electrical wires, it will protect them from damage while providing accessibility for splices.
Low-voltage wires are typically thinner and less durable to begin with, so protecting them is a good idea. Conduit may be overkill but it also makes it easier to pull new wires later on if needed: do a search on this site for people running into trouble with incorrect/insufficient thermostat wires for reasons why this is a good idea.
While the NEC does not concern itself with low-voltage wires (mostly, they are mentioned in a couple of places), nobody would fault you for providing the same levels of protection and accessibility for these wires.
It's not required, but there's no harm in doing so. I'd mostly detach them from the yellow cable and bring the nuts up above the insulation level in case you need to find them later.