EEVblog #1082 - What is the UL logo on products?

[EEVblog]

What does the UL type approval logo on consumer products mean?
What about TUV, ETL, GS, CCC and other marks?
Dave breaks down safety standards and compliance marks.

[Wilksey]

Question regarding these approvals.

If i went and purchased several components, such as an Arduino, a GPS shield, 4G Module, and say an RF module of sorts (ISM band), each would (hopefully) come with their own CE / RED certification where applicable, putting them together and selling them as a single product would mean that I as the "system designer" would have to certify the entire system and not rely on the individual components, especially if I add my own antennas, for CE you can get away with producing a product file and self-certifying, larger corporations will take it through to testing, some SME will just ignore the fact and not bother marking with CE.

How do computer manufacturers get around this?  They can come with a multitude of configurations including different plug in cards, different WiFi / Bluetooth combo cards etc, I can't imagine they have individually certified each possible build scenario, do they get away with self certification?

Does self certification apply to other approvals or do they have to go through a test house?

I can't imagine that a lot of products from UK manufacturers have gone through testing, we still use devices that are not CE certified marked and have never had any issues, does a product HAVE to be marked?

Adding all of the additional costs to the product can be quite a large sum of money particularly as most companies want to build to a low cost point.

[jeremy]

Dave, can you share the report for your multimeter?

[STMartin]

Hey, that's where I work.

If anyone with some pull at NBK could get Dave in for a tour, that would be fantastic. Just tell me first, I want an autographed multimeter.

[palpurul]

As Dave said there is no shortage of these markings and certificates.
My question is how does one cover every country in the world. For example, EEVblog multimeter can be shipped anywhere in the world, but it's got only 3 markings on it. Some of the products Dave showed has tens of markings on them some of them were spesific to Korea, Argentina etc. Does all products have to have those country specific markings on them in order to be sold in that particular country? Under which circumstances do you need to get these country spesific certificates/markings?

[Neilm]

If i went and purchased several components, such as an Arduino, a GPS shield, 4G Module, and say an RF module of sorts (ISM band), each would (hopefully) come with their own CE / RED certification where applicable, putting them together and selling them as a single product would mean that I as the "system designer" would have to certify the entire system and not rely on the individual components, especially if I add my own antennas, for CE you can get away with producing a product file and self-certifying, larger corporations will take it through to testing, some SME will just ignore the fact and not bother marking with CE.

Once they are assembled into an unit, the whole unit would then require qualification. This is because you could get re-radiation from components. Also with different antennas could change the transmission characterisics and cause the broadcast frequency to go out of spec. I once had to qualify a Bluetooth transmitter where the designer had mounted it on a non-standard (very thin) piece of FR4. The module as qualified was on a standard 1.6mm thick piece and the effect of that was to move the transmission frequency almost out of specification.

Does self certification apply to other approvals or do they have to go through a test house?

Depends on the standard - ones that are listed (for instance UL) only can be done at approved test housed. CE marking you need a technical file.

I can't imagine that a lot of products from UK manufacturers have gone through testing, we still use devices that are not CE certified marked and have never had any issues, does a product HAVE to be marked?

Adding all of the additional costs to the product can be quite a large sum of money particularly as most companies want to build to a low cost point.

Anything device "placed on the market" in the EU MUST be CE marked. This can be done by either by sending it to a test house or self certification. Technically, I think all that is needed is the Declaration of Conformity that says it meets the required standards. However if there is no techinical file or attempt to show the testing was done I would not want to argue that in court. The testing is used to produce the file to tell the judge that we (the designers, and the company) believed that the unit was designed to meet all the requirements of the applicable standards. Hence everytime I start designing a product, I do a search to try to ensure that I know all the standards (and in the case of IEC61010 all the various parts of the standards) that might be applicable. As Dave said, there are lots of parts and one product can have to meet several different parts. (For instance a multimeter would have to meet at least 3 sections -  the general part, the test leads would have to meet the test lead part and there is also a specific part that addresses multimeters)

[Wilksey]

Thanks for your response,

So how do PC manufacturers get away with it, surely they don't test every combination of build?

Also, I know of several UK companies that sell within the UK market that don't mark their products up as CE, I even worked at one, who sells equipment to a government backed outfit, how do they get away with it, is it simply just the fact that they are not on OFCOM's radar?  I doubt people go out of their way to look for CE marking.

Is it true that the product itself doesn't need to be CE marked, but the box it was packaged in does?  It was something that was said but never really understood if it were true or not.

I am all too familiar with the tech file and product environmental assessment report etc that goes with it for CE self cert, most things have gone for EMC testing, others have been self cert as passing based on the tech file and the certificates available from the component manufacturers.

[orion242]

Great topic Dave.  Look forward to the discussion here because it seems like its muddy waters at best.

[f4eru]

Perhaps a more comprehensive overview :
1) for the CE mark in the EU, the regulations have changed last year, you need a few more things :
- A product needs a CE compliance if it's in a category that needs it. Some products are in categories that do not need it, then you are not allowed to put it on.
- An importer or producer (if made in the EU) needs to put it's name and adress on the product. A legal reponsible inside the EU is mandatory
- Any seller(even private or donations) in the buisiness chain is responsible for CE compliance now. Prepare to be asked for documentation by your customers
- You need a user manual. If it's a technical product not a consumer one, english only is accepted.
- You need to have a risk management done for your product and ready to be shown on request
- You need to test your product, and document your tests. Self certification is possible in a lot of cases, but don't take it too light, you'll need to have that documented !
....

2) USA : In the US you need your product to be tested to UL standards by any NRTL lab only if this product is used at the workplace.
You don't need any certification if it's not used at the workplace (it's recommended though)
Concerning UL:
The UL is a scam IMHO, here's why:
- UL is the name for two separate things : UL standards and UL certification agency.
- Historically, the UL agency created the standards, and had a de-facto monopoly on the certification.
- Now, you can use any NRTL https://www.osha.gov/dts/otpca/nrtl/
- Typically, a UL certification for a product costs twice as much for the same service as any other NRTL ! That makes products expensive, so I encourage you to check the other ones.
- UL does not accept subassemblies that have been tested by another NRTL, so if you want an UL mark and your suppliers have their product tested by CSA, you're out of luck, you have to either change supplier, or pay more to your supplier and wait a long time so he makes a second certification. Other NRTLs are not like that, as far as I know. That creates a walled garden encompassing your supply chain you can hardly escape once you're stuck in.
- As far as I've understood, the people who control that compliant appliances are used in commercial and industrial buildings in the US sometimes do accept other NRTL's certification only after you hand them an official letter reminding them the law they're supposed to apply. Anybody has experience with this ?
- So in short:  UL rides on the historical confusion between the name of the standards and the name of the lab, and use a walled garden strategy to keep their prices high.

If i went and purchased several components, such as an Arduino, a GPS shield, 4G Module, and say an RF module of sorts (ISM band), each would (hopefully) come with their own CE / RED certification where applicable, putting them together and selling them as a single product would mean that I as the "system designer" would have to certify the entire system and not rely on the individual components, especially if I add my own antennas,

For RF transmitters, the rules are different than normal products, in EU as well as US.
You need in that case to have the transmitter tested to FCC or EC standards by an approved lab. Many countries have their own RF communication agency and regulation, so you often need more certifications, often directly by the comm agency, and not an independant lab.
This is additionnal to the standard product certification! That's why it's often very interesting to use pre-tested RF modules.
The integrator does most time not need to retest this, but he has to take in account restrictions on the antenna gain, placement etc...

example, for an ESP32 with antenna port :

https://www.espressif.com/sites/default/files/esp32-wroom-32u_fcc_wi-fi_bt4.0_certificate.pdf.pdf

You can find the certification documents here : ( tip : that is a great site to search, when your competitor's product has RF)
https://apps.fcc.gov/oetcf/eas/reports/GenericSearch.cfm

and you find :
https://apps.fcc.gov/oetcf/eas/reports/ViewExhibitReport.cfm?mode=Exhibits&RequestTimeout=500&calledFromFrame=N&application_id=5w6CW8a6gxr3RWCz0bfOsg%3D%3D&fcc_id=2AC7Z-ESP32WROOM32U

[f4eru]

So how do PC manufacturers get away with it, surely they don't test every combination of build?

That's a good question.
Often it's done like this:

1) OMG, we have millions of possible product combinations, how will we pass any certification testing ?
2) Ask your Lab, yeah, they tell you they test whatever you bring them, and it'll be expensive, so you better select it out carefully
3) make a matrix, and select the most meaningful combinations to test.

Often you want to select some worst case combination with all options, as well as all the component variation you'll have.
Yeah, you cannot achieve 100% coverage, but if you select a limited but sensible set of combinations, it's regarded as good practice, and accepted in the industry.