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Member

Join Date: Apr 2008
Posts: 6

UL listing

05/21/2008 7:45 PM

Here's one for legal folks- if I use an existing off the shelf unit and transfer the circuitry to a custom enclosure does the UL certification become void and open up liability issues?

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Anonymous Poster
#1

Re: UL listing

05/21/2008 8:01 PM

Unless you are a UL-certified panel shop, yes it does.

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Member

Join Date: Apr 2008
Posts: 6
#2
In reply to #1

Re: UL listing

05/21/2008 8:05 PM

I thought so, thank you. What would one do about a product where the end user has the choice of whatever they wanted to enclose the circuitry in?

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Guru

Join Date: Jul 2007
Posts: 4448
Good Answers: 143
#3

Re: UL listing

05/21/2008 9:27 PM

In general, you're not gonna get UL approval on something like that. Is this something you're selling to the general public or is this an OEM product?

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Anonymous Poster
#4

Re: UL listing

05/22/2008 11:47 PM

The question is a little vague and could be taken a number of ways:

1. You remove the certified componentry from its enclosure and install the same componentry in your custom enclosure.

2. You place the certified compnentry in its entirety in your custom enclosure.

3. You layout the same electrical circuits on a PCB in your custom enclosure.

Unfortunately, in all 3 scenarios, you probably will need to recertify.

Out of curiosity, UL or CE markings have become a necessity in most countries, but how many of you really believe they are necessary? I'm not saying that we don't need to comply with certain safety/emi/esd standards, but why can't companies do this testing themselves rather than pay the thousands and thousands of dollars it typically costs for certification?

For example, I had an instance where our certified product caught on fire and it was determined that the cause was an unfused external voltage line, so we added a fuse and I contacted our agency about updating our existing report.

The answer: "You need to have it re-evaluated" (for $3000+ of course).

My reply: Why? You didn't see any F***ing problem the first time you looked at it WITHOUT the fuse, how could it possibly be worse with one???

Response: *...................*

Don't get me wrong, ensuring that your product is safe to use and will not interfere with other devices is important, and I take that responsibility seriously, but at the same time, it seems to me that these agencies have found themselves a nice little scam. (You'll understand my point if you ever go to the test facility to observe your testing, and you observe the technician studying for his finals rather than watching your equipment for problems).

In other words... Agency approval is almost like insurance, You pay a lot of money for practically nothing, until the s*** hits the fan.

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Anonymous Poster
#5

Re: UL listing

05/23/2008 3:42 AM

The UL labels are not transferable. Therefore it becomes void. Contact UL regarding certification.

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Guru
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#6

Re: UL listing

05/23/2008 5:14 AM

"but why can't companies do this testing themselves rather than pay the thousands and thousands of dollars it typically costs for certification?"

I don't know the rules where you are but in the UK CE marking can be done by the manufacturer, we CE mark our own equipment.

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Anonymous Poster
#7
In reply to #6

Re: UL listing

05/23/2008 11:13 AM

"but why can't companies do this testing themselves rather than pay the thousands and thousands of dollars it typically costs for certification?"

They can, but they have to become a UL-Certified shop.

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Anonymous Poster
#8
In reply to #6

Re: UL listing

05/23/2008 2:14 PM

Dunno, but it could have something to do with independency. Possibly also what the company's liability insurer would prefer or demand. Again, the best source is UL itself...very helful people, too.

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Active Contributor

Join Date: Jun 2008
Location: Daytona Beach, FL
Posts: 24
#9

Re: UL listing

06/06/2008 10:07 AM

Here are some thoughts for UL and FCC Part 15 Certification. In general, UL is not mandatory in the US. FCC Part 15 certifications is required if your electronics falls under its requirements. Here are some thoughts from a company called PSE that does this type of testing.

US/Canada

The only mandatory requirements in the US and Canada are compliance to the FCC Part 15 rules for unintentional RF emissions. In Canada the rules are a mirror image of the FCC rules, so compliance to FCC Part 15 automatically results in compliance to Industry Canada ICES-003(no extra cost). This emissions test takes about one day to complete and results in PSE issuing a formal report which you must keep on file for the life of the product as proof of compliance.

It is also common for a manufacturer to obtain a safety approval for the US and Canada. It is not mandatory, but will enhance the marketability of the product and will serve to help your customers should their facilities/installation be inspected. The most well known safety certification agency in the US is UL, but there are 16 other organizations that compete directly with UL (see attached brochure). They all test to the same standards but issue different looking marks. Some of the bigger competitors are ETL, CSA, TUV, etc. UL is currently the most expensive and slowest to work with. PSE has persuaded most of our clients to use one of the alternate agencies, TUV America in particular. They are much easier to work with and less expensive. PSE has recently added a TUV engineer to our in-house staff, so 100% of the approval process can be done here in Florida. TUV is the UL of Europe, so to speak, and working through them we can get a single certification that covers the safety requirements for Canada, the US and Europe (they call this the CUE mark).

Europe - CE

In order to apply the CE marking, which is required for all electrical devices sold in the European Union, you will need to meet a number of Directives. The two main Directives that apply to most electrical products are the Low Voltage Directive(LVD) and the EMC Directive(EMCD). The LVD deals with product safety; protecting the user from fire or shock hazard. The EMCD deals with RF emissions and electrical immunity (proving the product is immune from various common electrical phenomenon such as ESD). Once I have a clear understanding of your product I will research the existing harmonized standards and recommend the best test plan. By proving your product meets the requirements of European harmonized standards you will be eligible to Self Declare compliance to the EMCD and LVD. In essence you will have test reports from a recognized test lab which will support your declaration that the product meets the essential requirements of the Directives and can therefore bear the CE marking.

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