Non-UL Certified Light Fixtures

THANK YOU

If the "personal project" includes installing them in your home or outbuilding you could have an issue. If you were to sell the home and there is later a fire caused by these fixtures, you could be liable in court.

Most (I believe all) states mandate the National Fire Codes as law. These codes require "listed" materials only be used in buildings, dwellings, etc.

If these fixtures are being used in some other fashion, you may be OK.

Yes, you most certainly can import non UL fixtures into the US.

You just cant use them for lighting (electrically connected) legally in the US.

Can you point us to the regulation or law that states this? It would be most helpful to know the details from the source.

UL, CSA, etc., are laboratories or companies that just provide and conduct device testing services according to their own sets of standards.

Unlike NFPA, which sets certain standards and regulations that must be conformed with and followed here in the USA.

Vsar,

No, the standards are industry-recognized, and usually written by third parties (sometimes manufacturers but more commonly professional associations). The testing laboratories do not write their standards.

--JMM

JM - There is no argument nor difference in opinion about its creation, recognition, etc., of such standards! Be it UL, CSA, etc,.

At issue I believe is whether it is unlawful or not to import or to use Non - UL tested /approved electrical devices.. - thus I repeat my previous comment that stated;

Again "having a UL or any other seal of testing approval is not a Federal requlation that can be found in its registry" to serve as a regulation or law that needs to be adhered to. However, Any private entity as well as any local municipality may and can also adopt / use and enforce the usage of certain UL standard or testing seal requirements built into their local housing or building codes".

vsar

Thanks for doing the leg work WJ.

I'm not in the office and do not have my ference material.

Regards - KJK

No Prob...

You can import non UL fixtures, but legally you cannot use them in the US, Canada and in any countries which use NEC codes or IBC codes.

Any products carrying the UL seal of approval only indicate or signifies that it is a good quality, well designed product that utilized sound engineering design, produced using good manufacturing practices.

It is not Illegal for anyone to import, use or sell Non-UL labeled products here in the U.S. - The use of non UL approved product is self- discretionary, and not controlled nor governed by the government and therefore not against any Federal laws.

That is not, at all, what a CE UL or any other label indicates. Don't know where you would get that idea.

The mark simply means the product has passed a battery of tests, and essentially didn't blow up in the test rack.

I have had products tested by Underwriter's Lab. Have you?

Yes, I concur that those labels only indicate that a particular product has been submitted and has passed a particular testing protocols or standards.

Also, although I had required all devices being brought to be used in my medical facilities be compliant, has met and undergone certain UL testing standard, not all were. Certain exceptions were made in which case my eng'g. department has to replicate all testing protocols. Yes, to answer your question, specially for imported medical devices, my dept. has from time to time did the line by line testing procedures just to satisfy certain UL criteria /standard.

That's all well and good. However, unchallenged, your previous statement would have had a completely different meaning.

Someone might have inferred that the labs did a complete engineering review of every device onto which the mark was applied. This is not the case.

CE marking is even more misleading than UL. It means essentially nothing, and the mark is routinely applied to products which have not been certified in any way.

Yes, I'm a cynic. Yes, I'm a pessimist. Yes, I'm a realist. But, I'm rarely disappointed.

..., use or sell Non-UL labeled products...

We are not discussing "products" here, we are discussing "Light Fixtures".

If you install non-listed light fixtures in a new residence or commercial building, you will not get a Certificate of Occupancy. The building inspector will fail the project until the equipment is replaced.

This requirement exists to afford the building occupants a measure of safety, as the electrical system is less likely to cause a structure fire.

Comments made were applicable to all electrically operated devices. As simple as light fixtures or to a more advanced medical device.

Again having a UL or any other testing seal of approval is not a Federal requirement nor contained in its registry. Any small local municipality may adopt / use and enforce certain UL testing seal requirements in their housing or building codes. This is just a matter of passing the buck or the burden (expense in terms of responsibility) to their customers. They are adapting such practices since they do not have or lack the necessary technical expertise. First hand knowledge gained from being a member of a city Utility Advisory Committee in Florida.

"Small, local municipalities" like the State of Florida, Commonwealth of Virginia, and every other state in the union have adopted NFPA 70 as law. This law cannot be overridden by any City Utility Employee, unless he/she wants to go to jail.

I have been involved in the design and construction of electronic and electrical systems into commercial and industrial buildings and plants for over 30 years. My work has taken me to almost every US state and about 2 dozen other countries. I have never seen a project where any electrical fixtures or equipment were allowed that were not listed. Nor would I consider such a thing. My reputation is worth more to me than saving a few bucks on non-listed equipment.

Besides, if only listed equipment is used and there is a failure, my liability as an engineer is not at stake.

NFPA / NEC are codes that are completely different from any UL testing certifications.

UL is a private testing entity. Anybody can adopt its seal of approval voluntarily as an acceptable "technical standard" of certain devices.

Unlike NFPA or NEC which are regulations that are codified, and obligatory to be followed. Any violations or non-conformance of which are subject to penalty.

Vsar,

Your wording appears misleading, which I hope is not your intent.

Anybody can adopt its seal of approval voluntarily as an acceptable "technical standard" of certain devices. You can ask U/L to test your product or device according to a particular standard, and if their tests show that that it passes, then they allow you (for a fee) to apply their label with their logo onto your product or device, with a description of which standard it has passed. To say adopt appears misleading.

Unlike NFPA or NEC which are regulations that are codified, and obligatory to be followed. NFPA is the National Fire Protection Association, one of the very few non-governmental organizations that writes codes (laws) and standards, and opens its membership to virtually anyone. The NEC is one of many publications they author, presented as a model code for adoption by any jurisdiction that wants to do so. In many places within the NEC, its wording requires products or devices used to be listed by a nationally-recognized testing laboratory. When it does so, then by reference the U/L (or similar laboratory's listing) is a legal requirement.

Another publication from NFPA is the National Electrical Safety Code, NFPA 70E. It is specifically referenced in sections of the Occupational Safety and Health Act, a Federal law.

--JMM

JM-

What I meant was, NFPA / NEC are Federal regulations that we must all abide with. While the UL in contrast is not, and therefore anybody can just pick and choose to adopt or not!

Now the statement about "anybody adopting as a local standard" was referring to some small counties, companies or entities that may opt to adopt and enforce same. As part of a local requirement that accepts any electrical device sporting a UL seal of testing approval.

As a former Eng'g director - I am well aware and familiar with all pertinent NFPA /NEC applicable regulations. On the other hand although it (UL) is not a federal law, I also have adopted certain UL, CSA, etc. seal of testing approval locally, as part of purchasing preconditions and prior to any equipment acquisitions and acceptance for my former institution.

Bear in mind this "UL" seal requirement was an adopted part for my local standards that were enforceable only within the bounds of my institution and its network affiliates.

Vsar,

I think you are saying that any customer or specifier can decide within his/her organization to voluntarily adopt or require the components to be U/L listed (labeled). If so, I fully agree.

I was referring to the situation that would occur if your customer or location was within a governmental jurisdiction which had legally adopted the NEC as the standard for electrical work. If so, then the NEC's requirements that devices be listed by a nationally recognized testing laboratory such as U/L becomes a legal requirement independent of any voluntary adoption of U/L listing by a customer or specifier. There is no Federal Government regulation requiring the use of the NEC; indeed in many states, there is not even a state government regulation requiring the NEC.

I think we are on the same page here.

--Thanks, JMM

JMM,

I don't think you are correct. I have worked projects in most of the 50 states, and have yet to see a state where following NEC is not state law.

The reason most people don't know this is because the requirement exists in the state fire codes, which are also law.

JMM,

It is understood that NEC or NFPA 70 standards are adoptable standards by any entity. Having agreed on that, it is quite clear that if any of the states in the country decided to "adopt" such practices then it becomes a part of their codified local laws and regulations that in turn need to be enforced.

IMHO also believe that the NEC standards by itself, being a sub-section of a broader NFPA, is not a US law per se. it only becomes a law once adopted to be part of a local regulation and enforce within the bounds of that local community.

Friend,

Lyn is essentially wrong in his response. NFPA 70, the National Electrical Code, says quite clearly in Section 410.6 "All luminaires and lampholders shall be listed." There are no exceptions or other words in that section! I believe that an inspector would have the authority to go to a store and require them to remove from sale any light fixture that has not been tested and listed. Ultimately, the responsibility for safety rests upon the owner of the property. Anything that is done in contravention to the codes can leave this owner liable for damages. Although the contractor has responsibilities and the inspector has responsibilities, these do not relieve the owner of the ultimate responsibility.

Now, as a practical matter, I have run into jobs in which the light fixtures were not listed, and a casual inspection of them showed that they would not pass the minimum standards of the NEC. Also, remember that the NEC is written based on the experience of people in the electrical trade. After a number of years, it is quite possible that something thought to be safe will be found to be a source of problems and is therefore no longer accepted by the code.

--JMM

I won't dispute what you say. However, I don't believe that the UL mark is required for importation. And, this is a personal project. Doesn't make it right, or safe, to do so.

When all else is questioned, call your insurance company. They will give you the answer of coverage in a lawsuit