UL 508A - Listing Question

[SAAPI]

I have a control product that is fully listed under the applicable UL standard - and I spent a lot of money to do this. One of my competitors has imported a product with a "CE" listing - not UL listed - and placed it in a UL listed enclosure - then they have UL 508A shop put a sticker on the box. Is this legal ?


My assumption is that all components that go into a UL listed 508A panel must be recognized - am I correct - and if so - how the heck do I complain to UL about this ?

 

[Jraef]

I have a control product that is fully listed under the applicable UL standard - and I spent a lot of money to do this. One of my competitors has imported a product with a "CE" listing - not UL listed - and placed it in a UL listed enclosure - then they have UL 508A shop put a sticker on the box. Is this legal ?


My assumption is that all components that go into a UL listed 508A panel must be recognized - am I correct - and if so - how the heck do I complain to UL about this ?

Sounds a little fishy.
There are specific detailed procedures by which a UL508A listed panel shop can add an "unevaluated component" to a control panel assembly, and still list the entire assembly. In a nutshell, the device usually must be wired behind a Class 2 transformer and protected by a GFCI. If that was not done, someone has probably cheated in some way. Also, this procedure is something that panels shops can use to INCLUDE a non-listed component, not take on or bypass the LISTING of a component. If the competitor's box has nothing but the transformer, GFCI and the unlisted device in it, that is not technically what that procedure is for, but that is something they would have to take up with their UL inspector.

Every UL 508A control panel assembly label is registered, so if you feel that something has been done surreptitiously, you can contact UL and report it as a potential violation. I would start with whatever contact at UL you have from when you went through your own listing process. But it's hard to imagine that a 508 shop who went through the lengthy and expensive process of getting themselves listed would take on a risk of trying to gain the system like that and possibly have UL pull their label, which could put them out of business. The more likely scenario is that the labels are counterfeit. They make really good copiers now...

But, be forewarned, things like that have a nasty habit of backfiring on you. The law of unforeseen consequences rules supreme.

What type of component is it by the way?

 

[petersonra]

I have a control product that is fully listed under the applicable UL standard - and I spent a lot of money to do this. One of my competitors has imported a product with a "CE" listing - not UL listed - and placed it in a UL listed enclosure - then they have UL 508A shop put a sticker on the box. Is this legal ?

I do not believe it is a criminal act if that is what you are asking. If you are asking whether it meets UL508a listing requirements you have not provided adequate information upon which to base such a judgment.

My assumption is that all components that go into a UL listed 508A panel must be recognized - am I correct - and if so - how the heck do I complain to UL about this ?

Your assumption is incorrect.

The standard itself describes what components can be used. Some are recognized, some are listed.

Some things like fasteners require neither recognition nor listing.

There are also ways in which unevaluated components (neither listed nor recognized) can be used.

It is also possible to get UL to evaluate unevaluated component(s), and if UL agrees, you can use it under the conditions UL says you can in a UL508a panel.

If you believe the control panel shop is fraudulently or improperly affixing the UL label, you would complain to UL. Since you already have some connection with UL, it would probably be easiest to talk with your contact(s) and ask them how to file a complaint.

I will say this though. There are not a whole lot of problems in the US with people deliberately improperly affixing UL508a labels.

 

[petersonra]

Sounds a little fishy.
There are specific detailed procedures by which a UL508A listed panel shop can add an "unevaluated component" to a control panel assembly, and still list the entire assembly. In a nutshell, the device usually must be wired behind a Class 2 transformer and protected by a GFCI. If that was not done, someone has probably cheated in some way. Also, this procedure is something that panels shops can use to INCLUDE a non-listed component, not take on or bypass the LISTING of a component. If the competitor's box has nothing but the transformer, GFCI and the unlisted device in it, that is not technically what that procedure is for, but that is something they would have to take up with their UL inspector.

You can use any unevaluated component if it is in a class 2 circuit OR if it is powered by a GFCI if it cannot be put in a class 2 circuit.

There are some limits to this but they are generally not all that hard to abide by.

I don't see a problem with someone doing this. It does not in anyway violate the UL508a standard that I can think of. I do not see any attempt to "bypass" listing requirements as there is no attempt to claim that the assembly is a listed widget. The listed assembly is listed as an industrial control panel, and that is what it is.

It is also possible to get UL to evaluate an unevaluated component for suitability in a UL508a panel without getting the component itself listed or recognized.

 

[SAAPI]

Thanks for the help.



The controller is definitely line voltage - it does have a "CE" mark - and there is not a GFI. The controller has a plastic housing - and I don't see any flame rating of the plastic either.


I believe it's a legit UL 508A label - but maybe the panel shop just made the panel and gave it back to the firm - and they installed the controller?


The only marking is the 508A label - and the manufacturer of the enclosure listing - not the panel shop - I think this is also a violation (but probably minor),


Being a US manufacturer - this really gets me upset and if I try to go into the EU market - it will cost me 30K-50K for a "CE" mark - but a EU company can sneak into the US with this stunt.



Again thanks for the help - I really don't have one to ask questions like these.

 

[petersonra]

Perhaps some photos of the inside and outside of the product?

UL508a also allows for a listing of just a panel without an enclosure.

I don't see anything that would prevent the importer of this product from becoming a UL508a panel shop and affixing the label themselves to the assembly.

 

[SAAPI]

Loosely quoted below from the UL 508A standard - my take is that whatever they put in the box (electrical) must meet a specific UL standard. Actually my product would be fine - because it's listed under the standards in the Appendix. I question can you really put a class 1 unlisted device in a UL 508A listed enclosure - and if so why would I ever get my product listed - I should just put it in a 508A box and have it approved ?

"A component of a product covered by this standard (508A) shall comply with the requirements of that component. See Appendix (all UL standards) for standards covering components.

There is an exception - but

a.) Involves a feature of characteristic not required in the application of the component in the product covered by this standard or

b.) is superseded by a requirement in this standard."

 

[petersonra]

You can only get a UL508a listing this way.

If you think there is some kind of impropriety going on, the only venue for relief is UL.

 

[petersonra]

Loosely quoted below from the UL 508A standard - my take is that whatever they put in the box (electrical) must meet a specific UL standard. Actually my product would be fine - because it's listed under the standards in the Appendix. I question can you really put a class 1 unlisted device in a UL 508A listed enclosure - and if so why would I ever get my product listed - I should just put it in a 508A box and have it approved ?

"A component of a product covered by this standard (508A) shall comply with the requirements of that component. See Appendix (all UL standards) for standards covering components.

There is an exception - but

a.) Involves a feature of characteristic not required in the application of the component in the product covered by this standard or

b.) is superseded by a requirement in this standard."

The provision you quoted goes on to say:

4.5 A component that complies with the requirements of Appendix B is able to be used in a product
covered by this standard.

Appendix B covers using a GFCI with an unevaluated component.

There is also this provision:

44.2.1 Components and internal wiring located entirely within a Class 2 circuit are not required to be
investigated.

Please let us know how your complaint to UL about this goes.

 

[Jraef]

You can use any unevaluated component if it is in a class 2 circuit OR if it is powered by a GFCI if it cannot be put in a class 2 circuit.

D'oh! You're right. It's been too long now.

But if it is line powered, that will definitely mean a GFCI ahead of it, so if that is not in the panel, it's not valid. If it is, then there is not much that can be said, other than in my opinion, it violates the spirit by which the allowance is made in UL508A.

That imported device must be very very cheap if they can import it, hire a 508A shop to built it into a "panel", add a GFCI and list it, then sell it for less than you want to sell yours for. We're I you, I would focus on the likely poorer quality risk of something that cheap and try to emphasise to specifiers that the specific UL standard that you paid to have it evaluated for is there for a reason, and that putting a UL508A label on a box with an unevaluated component inside is not the same.

If there is no GFCI ahead of it, I would definitely contact UL. Trust me, they care about this issue, it's someting that degrades the value of their "product", the panel shop listing process. They are more stringent than a lot of people realize.

 

[SAAPI]

Thanks - if I'm reading the standard correctly it looks like there must be a GFCI in front of the device - along with I believe an isolation transformer - and there must be a pretty clear warning about the product.



On this panel there is no GFCI - no isolation transformer and no warning on the product.


I really don't want to get the panel house in trouble - but if you try and sneak unlisted products (and really cheap) products into the US - you should be prepared for the consequences.

 

[petersonra]

Thanks - if I'm reading the standard correctly it looks like there must be a GFCI in front of the device - along with I believe an isolation transformer - and there must be a pretty clear warning about the product.



On this panel there is no GFCI - no isolation transformer and no warning on the product.


I really don't want to get the panel house in trouble - but if you try and sneak unlisted products (and really cheap) products into the US - you should be prepared for the consequences.

cost is not really part of the equation as to whether this can be listed under UL508a.

It is possible that the component has been evaluated by UL and accepted under the UL508a program. Such an acceptance would only apply to that specific panel shop and only under the conditions UL has specified.

 

[SAAPI]

cost is not really part of the equation as to whether this can be listed under UL508a.

It is possible that the component has been evaluated by UL and accepted under the UL508a program. Such an acceptance would only apply to that specific panel shop and only under the conditions UL has specified.

I would assume UL would not accept a CE product - sort of defeats the entire reason for UL to exist - why would I list my product - if I can just get a panel shop to put my control in a box - this isn't a one shot thing - it's a standard product for them.

The device is also missing the Panel shop tags - just the serial number.

 

[petersonra]

I would assume UL would not accept a CE product - sort of defeats the entire reason for UL to exist - why would I list my product - if I can just get a panel shop to put my control in a box - this isn't a one shot thing - it's a standard product for them.

The device is also missing the Panel shop tags - just the serial number.

There is no limit to the number of identical boxes that can be built to UL508a.

I would be careful about just what you are complaining about as far as the markings go. The standard has a lot of options for what markings are required and where they can be located. A fair number of markings can be located in the drawings or instructions and not on the box itself.

You keep going back to CE. CE does not mean anything in the USA. It has no bearing whatsoever on whether UL will accept it as being suitable for inclusion in a UL508a listed panel.

having said that, it is likely that in addition to the CE mark that the product is made to meet certain IEC standards. It is possible UL has accepted those standards as being adequate and amended the file for the specific panel builder to allow that component in a UL508a listed panel made by that panel shop.

There is no reason that an outside panel shop has to be involved. Your competitor can become a UL508a panel shop. You can become a UL508a panel shop as well.

The panel shop program only lists to UL508a. If you want to have a component listed to some other standard, you have to meet the requirements for that standard.

 

[SAAPI]

There is no limit to the number of identical boxes that can be built to UL508a.

I would be careful about just what you are complaining about as far as the markings go. The standard has a lot of options for what markings are required and where they can be located. A fair number of markings can be located in the drawings or instructions and not on the box itself.

You keep going back to CE. CE does not mean anything in the USA. It has no bearing whatsoever on whether UL will accept it as being suitable for inclusion in a UL508a listed panel.

having said that, it is likely that in addition to the CE mark that the product is made to meet certain IEC standards. It is possible UL has accepted those standards as being adequate and amended the file for the specific panel builder to allow that component in a UL508a listed panel made by that panel shop.

There is no reason that an outside panel shop has to be involved. Your competitor can become a UL508a panel shop. You can become a UL508a panel shop as well.

The panel shop program only lists to UL508a. If you want to have a component listed to some other standard, you have to meet the requirements for that standard.

No markings on the box either - voltage - current - or manufacturer - just the UL 508A serial number.

Only marking I can find is CE - maybe UL accepted this - but I sort of doubt it - I think the panel shop is not handling this correctly.

Competitor not listed as a UL508A shop - I don't need to become a UL508A shop - I carry listings under UL standards with ETL and UL.

 

[petersonra]

No markings on the box either - voltage - current - or manufacturer - just the UL 508A serial number.

Only marking I can find is CE - maybe UL accepted this - but I sort of doubt it - I think the panel shop is not handling this correctly.

Competitor not listed as a UL508A shop - I don't need to become a UL508A shop - I carry listings under UL standards with ETL and UL.

If you want satisfaction you are going to have to bring it up with UL.

Just don't be too surprised if UL tells you what they are doing is acceptable to them.

Incidentally, if there are no power circuits, I don't think there is any requirement to mark the voltage on the panel, or the SCCR, since it would be not applicable. From what you are saying, it seems unlikely there are any power circuits.

I am not sure there is any requirement that the manufacturer's name be marked on the box either since the UL file number uniquely identifies the manufacturer. It is not that hard to go to the UL web site and enter the file number from the UL label and see who it belongs to.

 

[SAAPI]

If you want satisfaction you are going to have to bring it up with UL.

Just don't be too surprised if UL tells you what they are doing is acceptable to them.

Incidentally, if there are no power circuits, I don't think there is any requirement to mark the voltage on the panel, or the SCCR, since it would be not applicable. From what you are saying, it seems unlikely there are any power circuits.

I am not sure there is any requirement that the manufacturer's name be marked on the box either since the UL file number uniquely identifies the manufacturer. It is not that hard to go to the UL web site and enter the file number from the UL label and see who it belongs to.

The CE device is switching directly 115VAC - I would call that a power circuit - also it's the UL 508A serial number not the file number - the file number is nowhere to be found.

 

[petersonra]

The CE device is switching directly 115VAC - I would call that a power circuit - also it's the UL 508A serial number not the file number - the file number is nowhere to be found.

It is almost certainly considered a control circuit by UL508a.

I don't recall off hand if the file number is required to be marked on the enclosure.

I would want to take a closer look at it before I would declare it in or out of compliance.

Nothing you have said so far makes me sure it does not comply.

The only entity that can make that determination is UL.

 

[SAAPI]

I don't believe the file number is required - but the manufacturer's name is - along with the power requirements.

 

[petersonra]

I don't believe the file number is required - but the manufacturer's name is - along with the power requirements.

The standard does not require the manufacturer's name. This is what it actually says.

52.1 An industrial control panel shall be provided with a nameplate marking that includes the following:
a) Manufacturer?s name or authorized designation;

You might be right about marking the power requirements. I took a close look at the marking requirements and in some parts it seems to require it and in other places it is moderately vague about whether it is actually required for a control circuit.

Really, you are going to have to get UL in the picture if you want a definitive answer.