UL Listings Explained

Randall Whitehead, IALD, explains the omnipresent UL designation and what it means for your product offering.

Q.: Randall, what is UL, and why is a label from it required on light fixtures?

A.: UL (Underwriters Laboratories) is a testing facility for light fixtures (and other electrical devices) that vouches for the safety of the product. Electricians won’t install non-UL fixtures, and inspectors won’t allow them on jobs. Without a UL label, you have no idea how potentially dangerous a fixture may be.

There is a huge liability if the fixture catches fire or electrocutes someone due to a manufacturing defect. It is well worth it to make sure that the light fixtures you sell have a UL listing. They come in three varieties: the designation Dry Location applies to fixtures designed to be used indoors, Damp Location means the fixture can be used outside in an area protected from direct contact with water, and Wet Location guarantees the fixture can be used where it comes in direct contact with water, including exterior locations, showers, saunas, etc.

Occasionally, your company may get solicitations online or through the mail to purchase fixtures from foreign countries. Often these fixtures look wonderful and seem to be offered at a great price. But here’s where “buyer beware” really applies. They may not have a UL label, meaning that you would potentially be responsible if the fixture malfunctioned. Is it illegal for manufacturers to sell fixtures without UL testing? No.

Manufacturers in Europe, Asia, Malaysia and South America are not required to get a UL listing when selling to countries other than the United States because those countries don’t require it. Those manufacturers in other countries that do want to sell their goods here must go through the testing process when they introduce their lines to the U.S. market. Because it is so costly, what we see in the United States coming out of other countries is often one-tenth of a manufacturer’s product line.

They normally pick the line items that will sell best to help amortize the cost of the testing. ETL (Edison Testing Laboratories), another U.S.-based testing laboratory, is an alternative to UL. Approval from Canada’s own testing laboratory, CSA (Canadian Standards Assn.), is required on fixtures manufactured in that country or imported from other countries.

According to its website, CSA conforms to UL standards and is therefore recognized as safe for the U.S. market. I have personally found that some electrical inspectors won’t recognize ETL or CSA labels as valid alternatives to UL, even though they are. I think it’s like Coke. Their marketing is so pervasive that Pepsi, an equally refreshing brown carbonated beverage, gets less respect.

Randall Whitehead, IALD

Randall Whitehead, IALD, is a professional lighting designer and author. His books include "Residential Lighting, A Practical Guide." Whitehead has worked on projects worldwide, appeared on the Discovery Channel, HGTV and CNN, and he is regular guest on Martha Stewart Living Radio. Visit his website www.randallwhitehead.com for more information on books, upcoming seminars and the latest lighting trends.

Leave a Comment

Submitted by ltangorra on Thu, 01/05/2017 - 09:27

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Hi Randall, I want to import a lighting fixture made by a French Artisan to install in one of my clients' house. Needless to say it is not UL certified. She is worried about any liability she may have if anything wrong happens. Is she liable? Is there a special insurance I can buy or she can buy to cover that? Thank you, Lin

There are lighting stores or test facilities that will do a one-time certification on a light fixture. It's a few hundred dollars, but well worth it if the client really loves the light fixture.

Submitted by ltangorra on Thu, 01/05/2017 - 09:28

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Randall, I'm a glass artist with and active UL 1598-7.2 I've had for years, and love it's easy build "like a tank" guidelines. www.brottworks.com

I'm very impressed with the small amount of responses of yours I've read thus far, good job!!! It's amazing how often I hear, "We used all UL listed parts- so it's to code"- "See that UL mark?"

To others reading NO IT'S NOT!!!! Those small marks list parts, and are NOT holigram rdgpq2 (think I got that right?) stickers that list, and an AHJ needs to see to meet NEC.

Now for my newbie question, I've always told clients NO- were d/b in 7.2 of my 1598 file to list. But can't for this one, as it's a museum and nothing can mount to ceiling or walls, so I need to make five 9-foot-tall floor lamps that need to me moved once or twice a year for their fund raising events- so I'm digging into UL 153, and plan to call for my first field evaluation either on site or in my studio to list. Want to stay in Section 49 as temp test exempt- but "floor lamp" isn't easy to find in 153, sec 110? Do you have much experience in 153? And if so, what section does a floor lamp fall under.

Will and can talk with UL engineers, but I don't want to be too much of a pest on easy 153 basics... Best From New Orleans, Andy Brott

Submitted by ltangorra on Thu, 01/05/2017 - 09:29

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Hi Randall. I really want to 3-D print some fixtures, and then install CSA-approved low voltage 5W LED light strings inside of them.

Do I need to get a CSA approval or anything to sell these? Thanks! Please email me if you can. Cheers, Barry

Submitted by ltangorra on Thu, 01/05/2017 - 09:32

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Is there an agency that could take my product, evaluate it and then give me the rejects before applying for the official UL agency? Or the right way to go with it would be applying straight ahead to the official UL agency with my product? Thanks for any advice, Osher

Submitted by ltangorra on Thu, 01/05/2017 - 09:33

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Hi Randall, I work in interior design in the USA, and am specifying light fixtures all the time. All vintage light fixtures we buy we have UL wired. All fixtures we import ourselves from overseas we have UL wired.

However, we purchase lights on American websites that are legally sold here, but manufactured in another country that are not UL listed. My question is this, legally, do we have an obligation to UL wire these lights? For example: if a house caught fire due to a light manufactured overseas, not UL wired, but legally sold in America, could the owner ever be held responsible, and insurance be void?

It's a gray area I've never understood. Thanks Ben

Hello Ben, Yes, this is a gray area. First off UL, is not the only testing facility available. Both ETL and CSA are both fully capable of testing light fixtures.

It is not illegal to sell untested fixtures in the U.S., but there is a liability issue. Who takes responsibility if there is a fire related to a defect in the lighting fixture? Electrician's are reticent to install fixtures without certification labels because they then take on the liability.

An owner can sign a waiver to release the electrician, but they then become the responsible party. Insurance companies will not look favorably on a fire caused by a light fixture that is not labeled.

I hope that this helps, Randall

Submitted by ltangorra on Thu, 01/05/2017 - 09:44

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What about table lamps? Do they need to be CSA tested? So many stores sell non CSA tested units (as in the electrical components are CSA, but the base and electrical combined have not been tested).

Submitted by ltangorra on Thu, 01/05/2017 - 09:50

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Hi Randall! How does CSA certification apply to handmade table lamps?

I understand that certification/testing is required for fixtures, but is there a legal requirement for the seller of a table lamp to have it tested? If not is the seller liable should (on the off chance) something were to happen with the table lamp?

Submitted by ltangorra on Thu, 01/05/2017 - 09:55

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Is there a reason why I can not find an 8-inch can light that can be installed in a rated ceiling? The 6-inch is available from a number of sources, but the 8-inch is a problem. Dale Townsend [email protected]

Six is the new eight. Large diameter housings are not popular for residential settings.

You could find some in catalogs of companies who sell commercial products. Many of them would be rated to be installed in suspended ceilings, which don't require an IC rating.

Submitted by ltangorra on Thu, 01/05/2017 - 09:56

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Just removed a UL listed fan and light control switch from my daughters room. Luckily she smelled the impending electrical fire and noticed the control was extremely hot before our house burned down.. completely melted!

The fixture is approved for use in Canada only if it has a "cUL" mark which indicates it has been UL tested and meets Canadian standards - BC electrician.

Submitted by ltangorra on Thu, 01/05/2017 - 10:00

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This [article] was very helpful. THANKS!

Submitted by Sharif Salem (not verified) on Wed, 01/11/2017 - 17:14

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Hello Randall,
I was surprised to see such a recent article still containing the premise that UL is "THE" certification mark required in the US by inspectors. In the U.S., ETL is not just an alternative but is an EQUALLY "Nationally Recognized Testing Laboratory" recognized by OSHA and the Federal Government testing to the standards of the National Electrical Code. Although you mention them later in your post, the majority of your post is about UL being THE mark required by electricians and inspectors, "Electricians won’t install non-UL fixtures, and inspectors won’t allow them on jobs. Without a UL label, you have no idea how potentially dangerous a fixture may be." This is not only incorrect but also damaging to manufacturers who use ETL as their testing lab and those who specify, buy or sell their product. There are many educated electricians and inspectors who do know that the ETL mark is EQUAL to UL. Anyone rejecting a fixture with a non-UL mark provided by an alternate NTRL is not only doing so incorrectly, there is also an argument that they are doing so illegally. Ignorance of other testing labs’ certification is no excuse. It is time as fixture specifiers that we educate the masses rather than perpetuate the myth that UL is the be all and end all of lighting fixture certification. I am sure many of our colleagues have run into electricians and inspectors who are ignorant of these facts and have put projects large and small in jeopardy with many tens of thousands of dollars of product either pending installation on site or even already installed! I thank you for your time.
Sharif Salem – Lighting Specifier at LUXE cable + light, Miami, FL

Submitted by RJ (not verified) on Thu, 01/19/2017 - 07:08

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I'm trying to manufacture an aluminum cube-type framed pendant fixture with UL listed wiring and socket. I realize that the whole fixture needs UL, I just can't swallow a per-fixture cost of $10-15,000 I've been given as an estimate. Does that sound correct?

Submitted by tonna (not verified) on Mon, 01/23/2017 - 14:07

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Some overseas companies advertise their products (Light Fixtures) as "having UL," but then when I inquired further, they are using UL approved parts but the whole light fixture has not been UL approved. Just checking to see if that would still meet the code requirement?
Thanks!

Submitted by denis (not verified) on Mon, 05/08/2017 - 19:58

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Where can I find a list of Los Angeles certified contractors to wire my lamps or sconces with UL certification?
Thanks,

Submitted by melissa colvin (not verified) on Mon, 05/22/2017 - 18:50

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Hi
Can a European LED fixture {led 3, 7w 350 mA} be converted for use in the United States?
Thanks!

Submitted by Arash (not verified) on Tue, 05/30/2017 - 08:24

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Hi, lovely article!

My question is:
I am a working product designer based in Sweden Stockholm. I have designed a pendant fixture that have caught some interior designers attention in the US. Of course they ask if I have UL certification. And of course - I have not. Since we are talking about a couple of items only (7), to be produced for a restaurant space. How would I need to proceed? Im not a lighting manufacturer, and I only want to certify a couple of pendants for the US market. It's also worth mentioning that all of the parts inside the pendant are standardized CE and UL components. You mentioned earlier that you can send the fixtures to specific facilities that can arrange that for you. Do they need to assemble the fixture as well - or only to "check" it and then Okay it?

Thanks!

Submitted by R.Cafaro (not verified) on Tue, 06/06/2017 - 10:18

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Hi, Im refinishing several prewar II Wurlitzer Jukeboxes that have a round UL decal next to the serial plate on the back door. The original decals are in bad shape and will be lost in the refinishing process.
Q: where and or how can I get replacements?

Submitted by Jo kelly (not verified) on Sun, 07/09/2017 - 11:59

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I bought some solar patio lights that have no UL mark. I'm concerned because the little solar panel pack with rechargeable batteries sits on my patio roof. The package says to bring in during inclement weather. That seems to suggest this solar panel is not made for outdoor use. Could the solar pack with rechargeable batteries start my roof on fire?