UL Listing and Lighting

Hi Core

We are looking at bringing a couple lighting products to market (chandelier and pendant lamp) and we are currently incredibly confused about UL listing, CE marks, etc. We are a tiny start up with zero interest in paying tens of thousands of dollars for independent testing.

Can anyone shed some light on how important it is to have a product UL listed and what (if any) other options are available to a small self-producing home goods company trying to bring some lighting to market?

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Well first off, depending on where you are planning to sell some retail companies will not even shelf your item with out the listings.

Next part of the reason behind receiving the listing is CYA in case something goes wrong and someone gets hurt buy your product, or the item causes a fire.

Chevis W

I have heard these things. We mostly deal with indie retail shops so there is probably more flexibility than if we were chasing big box stores. Where I really see it being an issue is trying to get lighting spec’ed in hotels, retail, and restaurant. We do some design build in those areas and are trying to push the designers and clients to start spec’ing our self-branded stuff.

As far as liability in case of an accident we have product liability insurance so shouldn’t that cover our behinds in case of a disaster?

There may or may not be more flexibility with the indie retail shops… but if they sell items that are not listed then they open themselves up to the lawsuit, so you may see some push back from them. As for your product liability insurance you will want to check with your provider to ensure there is no loop hole and that you are still covered without the listings. The whole point behind the listings is to allow the manufactures to say that their product has been independently tested and is in compliance with the current safety standards. it helps to prevent potential law suits. I can’t imagine hotels retail and restaurants would ever spec’ and item that is not listed.

Also how much is your liability coverage… lets say your product burns down a hotel that cost millions of dollars, plus life is loss… they will go after you once the coverage runs out…

Definitely great points. Especially if we burned down a whole hotel. That would be a bummer.

Has anyone actually gone through any of the listing processes?

We are doing fab sales now so if we put a light up there it would be on sale in America and the EU so it seems like we would need UL listing and CE marks. We would literally never make that money back if we had to pay for the independent testing. I have also heard something about getting UL listing through the hotel inspection process. The hotel pays for the testing (this is more in the case of some big lobby installation or something) as part of the overall electrical inspection and then your product becomes UL listed.

Thanks again for the feedback.

You may also want to look into the fact that many times if you have the CE listing you do not need the UL listing. Also when you talk about independent testing are you talking about a company other then UL certifying it? i.e you pay a company to look at the product before you submit it to UL…
When I was doing electric houseware product we would do our own ul testing (per their guidelines) then submit the final design to UL for their approval. It never involved tens’ of thousands of dollars…

For the original poster; we have a UL engineer on our team that handles the process - it can be lengthy and expensive, but the cost drops after you do the first one (assuming there are some commonalities between your lighting products).

To the previous points, small indie shops might sell the goods but liability will quickly become a monster in the closet - it might come out or it might not but if it does it’ll definitely make a huge mess.

Feel free to email me if we can be of help.

To gain a UL certification most applications are done through independent accredited test labs. Prices vary but common to all is lower cost for very thorough, complete, accurate and easy to understand documentation. Generally they are faster and cheaper than submitting direct to UL, and there are probably several labs in your area.

Many jurisdictions have allowance for artist’s installations not requiring UL certification. What level of inspection if any does occur is entirely unique for each case.

There is also allowance for sale of goods without UL certification but with at factory review from electrical utility inspector. This is generally for very low volume manufacturers of specialized equipment, with variable allowances from what I’ve heard of about 5 - 10 per month. I don’t know the cost for this service. There’s also a hazard with this type of semi-certification: the electrical utility can refuse you if they feel you are a volume manufacturer.

Consumer goods imported to Europe require a CE mark. Without it the goods will not clear whatever customs inspection if they are caught.

Oh geez. This is a whole other can - o - worms. We have started selling overseas via Fab and some similar sites. These aren’t lights, but clocks. The movements themselves have a CE mark, but our branded product does not. Hmm.

Anyway, lights. I talked to the people at UL today. There is no way to get a UL mark on your product even using UL certified products like fixtures or sockets. Any additions or subtractions you would make from that set up would be considered a retro fit and void the UL listing. I think if we were to pursue UL listing we would select a fixture and create many iterations that are similar enough to submit as one group. This would then amortize the cost across several products and make it more feasible for a small company such as ourselves.

After talking to designers on our level, designers that are more established, architects, and design managers for very boutique hotels (who didn’t even know what UL was) I’m less concerned about a lack of UL listing hurting our sales. I am still concerned about the liability issues, and the regional UL underwriter seems like it might be a viable option. For now we are going to continue to develop and market the lights and if we start selling decent quantities go ahead and get the UL listing.

Thanks again for all the feedback.

This is something we will absolutely look into. The counts seem about right, we really don’t sell that much product right now because its not our bread and butter. I doubt if anyone investigated us they would feel we are a production shop. We are just a few guys with a little wood shop and a 4 x 4 cnc. It also seems like it could be really good for custom installations we would do in retail or restaurant environments.

Is the certification process a part of the overall permitting and inspection process for the build out or something the client would have to arrange and pay for separately?

Even if you choose to not have your product listed at this time, I would still recommend to at least build your fixtures to the standard - 1598. It’s not that complicated and I actually think the UL standard is laid out pretty good, at least better than IEC or CE.

Found this at the top of my first google search:

I have done some small run table and hanging lighting, employing single bulb corded sockets, and was referred to a contract lighting company out of the greater NYC area called Glucksman Lighting (look them up with your favorite search engine). I assume there are others like this elsewhere in the country, but they aren’t easy to find.

I contacted them to have some UL compliant lamp setups built to my spec, though to offcially UL “list” said lighting setup (assembly consisting of the cord, switch, socket, et al) was an extra per-unit cost, that I declined at least for the initial run. They even spelled out that the listing itself is mostly just paperwork and record keeping on their part, the physical product is assembled no differently listed or not, but there is definitelysomething to be said for personal piece of mind and less legal liability. They do have order minimums and their UL listing only covers the electrical portion of the product they are putting together, not the lamp shade/stand/structure that you are connecting it to, though I am unlear if that is nessesary, perhaps someone above can clarify?