I have a spray tan machine which I wish to sell in the USA. I have had the machine tested by a CE test house. Do I have to have a UL approval as well?
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6 Answers
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The National Electrical Code requires that all items installed in a building be tested by an NRTL, generally that means UL listed. This does not apply to your personal use items, but does apply to any fixed appliances or electrical equipment that is installed within your home or commercial facility. If your local jurisdiction has adopted the national electrical code then this requirement applies.
Maybe... Assuming this is a mains powered device? There is US Federal law and there are also local laws. If you only sell a few you may get away with not getting a Nationally Recognized Testing Laboratories (NRTL) approval (there are many NRTLs, UL is just the most well known). However, besides pingswept's point, local electrical inspectors may prevent business owners from using your equipment based on local regulations unless they see an NRTL mark (even though the Federal gov may not require it).
Check with the test house that did your CE approval, if they are big enough they may also grant NRTL marks (we use TUV Rheinland). Note that not using UL or CSA may cause problems in some jurisdictions that are old fashioned. We have a $4.5M medical device and the City of Baltimore wanted UL, CSA or MET Labs so we gave MET Labs the TUV test reports and a check for a few thousand dollars and they gave us an approval. UL is a pain to work with, I would go with CSA before UL (even though CSA is Canadian they can grant US NRTL marks in general). Also note that as part of getting an NRTL mark, you will be signing up for periodic (typically four times a year) factory inspections where the NRTL will make sure you are still building your product in the approved way. Of course you pay for that privilege.
I think the bottom line for mains powered equipment is, if you want the US to be a significant market, you want an NRTL approval. While getting the NRTL approval, throw in the Canadian approval, there are only small differences in the requirements and you open up both markets.
Eric
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\$\begingroup\$ RunDeep's answer is very good. Only thing I would like to add is i've heard that some insurance policies will not cover your house from fire if it was started by a device that wasn't NRTL approved. \$\endgroup\$– blak3rCommented May 24, 2011 at 20:11
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\$\begingroup\$ @blak3r What is the source for this comment? \$\endgroup\$ Commented Feb 23, 2015 at 20:04
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\$\begingroup\$ This answer is great, as a side. Does a device need these certs. if it's powered by a "sold separately" device, such as USB charger? \$\endgroup\$ Commented Jul 8, 2016 at 21:12
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\$\begingroup\$ If you aren't powered by mains voltage, e.g. 120 Vac, the NRTL approval is generally not required. See osha.gov/dts/otpca/nrtl/prodcatg.html for the list. Don't forget the FCC has requirements as well, for instance anything with a microcontroller will most likely need testing... fcc.gov/oet/ea/rfdevice \$\endgroup\$– RunDeepCommented Jul 10, 2016 at 6:31
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No, UL approval is not legally required. It's only common because many large companies will not buy equipment that has not passed UL's safety tests.
answered Feb 24, 2011 at 14:57
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3\$\begingroup\$ Just to clarify, "large" companies are not only end users but also resellers. Wall Mart, for example, would probably not sell your product without it being certified to their satisfaction. \$\endgroup\$ Commented Sep 5, 2012 at 13:21
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As far as I know, there is no legislation mandating certification by UL or any other agency, public or private, prior to sale of consumer electrical goods in the US.
The rub comes when one wants to buy product liability insurance and finds that it's unavailable without certification by, say, UL, the reason being that the insurance underwriters are simply unwilling to take the risk of being sued because someone's house burned down because of a rogue widget.
Without some agency like UL and their imprimatur attesting to the safety of the widget, getting goods to market, unless you want to sell them out of the trunk of your car, is going to be difficult, at best.
To add insult to injury, if you manage to get a widget into someone's home and the house burns down, for any reason, the homeowner's lawyers are going to have a field day with you and you're likely to have to spend more time in court than you want to, and even more time on the street, since they'll strip every speck of meat from your bones, just to prove they can.
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\$\begingroup\$ What's more, UL is Underwriter's Laboratories, as in, "started by the insurance companies to deal with the question of what is insurable". \$\endgroup\$ Commented Feb 6, 2023 at 3:58
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You cannot be sure about selling in the US without an NRTL mark (it doesn't have to be UL per se, but has to be a recognized mark). You can be sure that if the product has a recognized mark, you can sell it.
The CE mark has no weight in North America.
answered Feb 24, 2011 at 20:32
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To add to what others have said, anyone who does buy and install a system that is not certified will probably not be able to get insurance coverage.
UL was created for insurance purposes.
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Insurance companies can not deny coverage based on certification. It's strange as UL or any other certification house will stand by your side if for example a toaster catches fire but you have no recourse against them as they are not liable for the products tested. Hhhhmmmm so why do manufacturers pay for this? And the costs are passed to the consumer. Another way of an private company using scare tactics to make money.
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1\$\begingroup\$ Could you cite a source for this? \$\endgroup\$ Commented May 11, 2017 at 2:13