We recently shared a list of US Consumer Electronics Compliance Basics that importers should know about, especially, in this case, American businesses who are selling into the US market. One of the key requirements that many importers need to comply with is UL, and in this post, we’re going to be discussing UL compliance in more detail.
What is UL?
UL stands for Underwriter’s Laboratories. UL solutions is a U.S.-based company that’s been in business since 1894, and its speciality is focused on product safety.
UL’s mission statement helps one understand who they are and what they do:
Our mission is working for a safer world. These principles drive every decision we make:
- To promote safe, secure and sustainable living and working environments for people by the application of science, hazard-based safety engineering and data acumen
- To support the production and use of products which are physically and environmentally safe and to apply our efforts to prevent or reduce loss of life and property
- To advance safety science through research and investigation
- To concentrate our efforts and resources on public safety in those areas where we can make valuable contributions
- To work with integrity and focus on quality to enhance the trust conveyed by our certification marks and services
- To charge fair prices that allow us to meet our obligations, sustain our growth, and invest in safety science and education
- To invest in our people and to encourage our people to invest in themselves
- To be a good example of corporate citizenship and social responsibility
As you can see, they are a testing body that is devoted to safety. Importers will send their product to an accredited laboratory where they will run a whole battery of safety tests that ultimately result in the product either failing because it does not reach UL compliance requirements or it being granted a UL certificate. Products that reach UL compliance will be listed on the UL website and can be checked by businesses and consumers.
Why UL compliance is necessary for (most) product safety testing
A lot of people may wonder whether or not their product actually requires UL compliance or not. This really depends on if your product can feasibly represent a safety hazard, however unlikely that may seem.
For example, the engineers at Samsung almost certainly didn’t expect the Galaxy Note 7 to be a safety hazard, yet its design was defective and it caused the batteries to combust and even explode in some cases. Therefore, it’s fair to say that a lot of consumer products, especially electronics that run from a Li-ion battery or AC mains power, will need to comply with UL before they can be sold.
Is UL compliance only for the US market?
Yes, UL compliance is usually required for the American market only, although importers to other countries may benefit from putting their products through UL safety testing, too, as it’s quite rigorous.
Is UL certification mandatory?
Actually, UL testing is NOT mandatory. However, as you might be selling your product to retailers such as Amazon and Walmart, most of these retailers in America require UL certification if your product could pose some kind of a safety hazard; for example, it has a lithium-ion battery in the product, or it’s a type of product that has a power supply that plugs into a wall socket, etc. You know that these can be a hazard after seeing the Samsung case mentioned before.
Retailers will almost certainly require it because it protects their customers from unsafe and protects them from liability if a certified product does end up being a hazard because otherwise they could be sued for selling ‘unsafe’ products.
How much does UL testing cost?
The UL testing cost and certification are very expensive in reliability and safety testing terms. It costs anywhere from, for example, around $5,000 up to $50,000 or more to put a product through UL testing. Here at Agilian, we worked with a client on a large project which was a huge power supply for the home and the UL certification for that product was over a hundred thousand dollars!
If your product requires UL certification if it’s a really small item the cost will probably range anywhere from a couple of thousand dollars to five thousand dollars and you probably need anywhere from one to five samples per test which also have an associated cost. There may be several tests and the number of tests will increase along with the product’s complexity (this varies per product).
For larger products, the UL testing cost will be a lot higher. For example, if the large home power supply we worked on was not tested by UL for safety, consumers would be putting a huge lithium-ion battery in their homes that, if it explodes, would basically burn down the whole house. Therefore, the testing that has to go through is very complicated and includes multiple tests and, when you have to combine these UL tests with a whole set of other tests like FCC and some other country-related compliance tests, the UL test itself could cost over fifty thousand dollars or so, but then with the combined other tests that on all of its components, your total testing bill could be in the order of $100,000 or more. With a larger product, it’s going to be about the economies of scale. Yes, $100,000 on testing is expensive, but for big-ticket items like the home power supply, it becomes affordable once these are mass-produced and sold in decent quantities.
On the positive side of things, you only need to obtain UL certification for your product once and the whole purpose of it is to come up with a label that has your UL listing which will be registered on their website.
What if you DON’T do UL testing?
As mentioned, UL compliance is technically not mandatory for the US market, therefore you may wonder what the risks are if you decide to save the money and not obtain UL certification. There are a couple of risks:
- If it turns out that your product has an issue you didn’t catch or know of that causes a safety hazard and risk to consumers, such as fire, explosion, or anything that could actually hurt people or property, you could be liable to a massive amount of lawsuit and quite possibly jail time.
- In some cases, UL certification is actually a must. Retailers will NOT buy your product which could mean that you cannot sell it in the USA even if you want to. A good example is electrical products that you plug into AC. Retailers will not be interested in a product like this that doesn’t have UL compliance, and it may even be that the US customs won’t allow them to be imported if a retailer has requested UL certification documentation and they cannot see it. So it’s very important to check with retailers what their UL testing requirements are early on because you don’t want to wait too long and then when you’re about to ship the product, suddenly find out that you need to put the product through UL certification.
How long does UL testing take?
UL certification typically includes quite a lot of tests, it’s not just one or two tests, hence the relatively high cost. But there’s also a time aspect as well, so let’s say you had to do UL testing, it really isn’t possible to do it ‘in a hurry.’ Even for small and simple products you can expect UL testing to take between around three to four weeks.
However, for a larger product, such as the home power supply we mentioned we’d worked on for a client, you’re not talking about a couple of tests and needing just a handful of samples so it could easily take several months to complete UL compliance testing.
Can any lab handle UL compliance testing?
You must use a UL-accredited lab for your certification, but there is a large network of labs that are authorized to supply the certification across the world and we often help select the right one in China for our clients.
However, that doesn’t mean that you can’t start preparing your product to comply with UL testing requirements before you even engage that lab. If you have a very complicated product and you want to do some UL screening to make sure that it’s going to pass before making that large payment to UL, there are plenty of labs that can do UL-level testing but are simply not authorized to give out certifications.
Does a product ever need to be re-tested?
Testing for UL compliance is only required once per product. But, as soon as you make any changes to that product, a whole new certification will need to be obtained and its full cost paid again.
There are two scenarios where this could happen:
- Scary scenario. Let’s say you have just put your new product through the UL certification which costs you fifty thousand dollars. Then, all of a sudden, the engineering team decides that they need to make some minor changes, change some components, or do some cost reduction changes before the product can go into full production. In this case, the product’s current certification is voided and it will need to go through the full UL compliance testing process again for another fifty thousand dollars!
- Normal scenario. You design and develop a second version of your product which has gone through some design changes, and the form, fit, and function might be different from the first version. This V2.0 product definitely requires UL testing again, because even if everything looks the same from the outside, internally and feature wise some items have been changed.
When should you start doing the UL testing?
The best time to do UL compliance testing is when the Prototype stage has been completed and you have a functioning working product where the design has been locked in and you’re about to go into full production with this particular design, so you’re not thinking about making any more changes.
What some companies will do if they’re pretty sure that their product is going to pass with no issues is to take a risk and do UL testing in parallel with starting production.
On the other hand, most companies typically start with a very small sample size in production and they use those pieces for verification and validation purposes by the engineering, reliability, and other teams. Then, while the teams are reviewing and validating the product, the UL certification is actually happening at the same time. Once all of this data comes in, you passed validation, verification, and the engineering and reliability tests and full production starts with very low risks. The benefit of following this is that the UL compliance work can take place at the same time as other important verification and validation work and you’re not left in an inefficient scenario where everybody just stops for several weeks while a UL certification or other testing and validation gets done. One of the other benefits from this is when you do have the green light to start mass production you’ve also got your learnings from the pilot run about how well the manufacturing processes are standing up to the needs that that you’re going to have and you’re not going to have any safety issues related to your product when you start producing in larger quantities.
Any tips on reducing/avoiding UL testing costs?
If you really want to reduce or avoid UL testing and its costs for whatever reason, here are some of the suggestions we can make; bearing in mind that UL is, more-or-less, mandatory for many importers whether they like it or not.
Most likely you are looking to save time or money by avoiding at least some of the UL testing costs. So, here are a couple of tips:
- Instead of you creating, designing, and building the power adapter for your product from scratch, a smart choice is to just purchase a UL-certified power adapter/supply. Then this element of your product will not need to be tested.
- If your product can actually work with a USB, meaning that it charges via USB, then you should use a USB charger as opposed to a plug for mains power. This way all the adapters can be UL-certified by the supplier and your device is basically being powered by USB you shouldn’t have to worry about any kind of UL certification for your product as far as the power goes.
- In some cases, you might take a chance or risk not being UL compliant because UL is not mandatory and you are not planning on selling to any retailers in the USA. So, for example, you’re selling online and individuals are going to come to your website and they’re just going to buy one or two of your items. In that kinds of situations, there might be a chance that you may not need the UL certification as long as there is no obvious safety hazard from your product for the users. Agilian doesn’t advise this, but it is something you can discuss with your engineering and UL technicians and see what they think.
Conclusion: UL compliance is almost always worthwhile for US importers
UL compliance is extremely important because of the fact that its focus is on safety and hazards can come in so many ways. It’s not always an explosion or fire, it could be chemicals or other hazardous materials in the product such as lead in the paint. It’s also clearly not limited to consumer electronics, although products that use Li-ion batteries and mains power are obviously potential fire, explosion, and electrocution risks. Consider children’s products and toys, for example. Can you in good conscience sell a product which could harm children, however unlikely that is? That would be irresponsible, so if you believe that there are any feasible kinds of risks to consumers’ safety, definitely go through UL certification.
Disclaimer…
We are not lawyers. What we wrote above is based only on our understanding of the regulatory requirements. Agilian Technology does not present this information as a basis for you to make decisions, and we do not accept any liability if you do so. Please consult a lawyer before taking action.
