UL & Associated Certifications- is it necessary in this case?

[RomanyCaravan]

Greetings:
New to this forum. Very happy to have found it! I have just patented a 'kind of' night light.

• We provide the paint effect finish to a 4"x 4" modular junction box (very commonly sold at any Home Depot, Lowes or any hardware store. It is made of Galvanized Steel). We do not produce the box, but only the finish to the box.
• We purchase from a vendor a clip-in outlet cord and bulb combo (5 Watt), which comes in a sealed package.

We reship the above painted juction box and clip-in Outlet cord and bulb combo (5 Watt) which is sealed and has never been opened, to our customer.

Question. Since we only refinish the modular box and don't manufacture any of the action electrified elements, do we need to get this product 'as a whole,' CERTIFIED?

Pictures attached...

Thanks in advance for reading and responding,

Mark

 

[petersonra]

Greetings:
New to this forum. Very happy to have found it! I have just patented a 'kind of' night light.

• We provide the paint effect finish to a 4"x 4" modular junction box (very commonly sold at any Home Depot, Lowes or any hardware store. It is made of Galvanized Steel). We do not produce the box, but only the finish to the box.
• We purchase from a vendor a clip-in outlet cord and bulb combo (5 Watt), which comes in a sealed package.

We reship the above painted juction box and clip-in Outlet cord and bulb combo (5 Watt) which is sealed and has never been opened, to our customer.

Question. Since we only refinish the modular box and don't manufacture any of the action electrified elements, do we need to get this product 'as a whole,' CERTIFIED?

Pictures attached...

Thanks in advance for reading and responding,

Mark

In general, I think you can paint the junction boxes without having to worry about the listing being affected.

The rest of it is hard to say, but it appears you may be creating a luminaire and they are required by code to be listed.

ETA: Can you post a picture of the completed assembly, not as shipped, but as installed?

 

[Jraef]

I agree with Bob, it MIGHT be what's considered a "luminaire" if you sell it as a unit, in which case it would likely need a separate listing. If you are selling the components and the electrical portion is an already listed assembly that is a "pass through" as far as you are concerned, you may not. Then again if that assembly is NOT separately listed, then you may be on the hook again for selling it as a "kit" that users assemble, but is not listed as an assembly.

It's the same for furniture mfrs who, for example, sell a desk assembly that has a built-in light fixture. If they buy and supply a LISTED complete light fixture and mount it to their furniture in the approved fasion, that's fine. If they by the un-listed COMPONENTS of a light fixture and ship them with the desk telling the end user to assemble it themselves in the field, they then assume the responsibility (and liability) for the full assembly.

 

[RomanyCaravan]

Fully composed Luminaire

Fully composed Luminaire

In general, I think you can paint the junction boxes without having to worry about the listing being affected.

The rest of it is hard to say, but it appears you may be creating a luminaire and they are required by code to be listed.

ETA: Can you post a picture of the completed assembly, not as shipped, but as installed?

Bob:
Thank you for the reply. Attached is our fully lighted Luminaire with Clip-In Cord w/bulb (5W) installed... What do you think?

Many Thanks,
Mark

 

[RomanyCaravan]

Pass Through or a luminaire unit?

Pass Through or a luminaire unit?

I agree with Bob, it MIGHT be what's considered a "luminaire" if you sell it as a unit, in which case it would likely need a separate listing. If you are selling the components and the electrical portion is an already listed assembly that is a "pass through" as far as you are concerned, you may not. Then again if that assembly is NOT separately listed, then you may be on the hook again for selling it as a "kit" that users assemble, but is not listed as an assembly.

It's the same for furniture mfrs who, for example, sell a desk assembly that has a built-in light fixture. If they buy and supply a LISTED complete light fixture and mount it to their furniture in the approved fasion, that's fine. If they by the un-listed COMPONENTS of a light fixture and ship them with the desk telling the end user to assemble it themselves in the field, they then assume the responsibility (and liability) for the full assembly.

Thanks you for the thoughtful reply:
So what I think I am reading is that if we ship the painted box with installed artwork (the portion that we do here at Rc). Then enclose also a sealed light harness with bulb in the box as well, we're on the hook for creating a separate UL listing? or are you saying that since the clip-in bulb and wire harness are already UL approved and the customer clips it in (it becomes a Pass through?)

Please advise and thanks again for the reply!

Mark

 

[Jraef]

Thanks you for the thoughtful reply:
So what I think I am reading is that if we ship the painted box with installed artwork (the portion that we do here at Rc). Then enclose also a sealed light harness with bulb in the box as well, we're on the hook for creating a separate UL listing? or are you saying that since the clip-in bulb and wire harness are already UL approved and the customer clips it in (it becomes a Pass through?)

Please advise and thanks again for the reply!

Mark

Yeah, I THINK that if the cord / lampholder assembly is itself ALREADY listed as an assembly, you are not responsible for re-listing it. You assembly could be considered similar to a "night light cover" that clips onto an already listed night light.

That said, if what you are REALLY wanting to sell is the art part of this, you could consider finding a low voltage LED based light source for it, one that comes with a UL listed "wall wart" Class 2 power supply. Then your "fixture" becomes low voltage and not subject to needing listing.

 

[petersonra]

My opinion here. I think you have created a Luminaire. In its current form I see no way that UL would List It. It just has too many safety issues. The easiest things to fix are the extra holes that can't be there. I don't think they would accept the idea of the backlight behind a piece of plastic either unless that plastic was UL recognized as fire resistant. If this is intended to go into a wall so that only the surface is visible it would be in violation of NEC restrictions on putting cords inside of walls. I also don't believe that you would be allowed to just click the light inside there like that. I think it would have to be secured in some way. There may be other issues as well but don't come to mind right this second. I don't think there's anything really wrong with the basic idea but I think the implementation has major issues.

 

[mopowr steve]

This kinda thing can go south.
One time I was having a few beers with some friends at a dinner table. And his wife made or bought one of those Potpourri and Christmas lights in a jar (remember those?) seems like all the craft stores were selling.
Well.......after I don't remember how many the thing went up in flames.......so just a word of caution when sticking a bulb (regardless of how small it is) in something cooling space needs to be considered.

 

[RomanyCaravan]

Venting?

Venting?

This kinda thing can go south.
One time I was having a few beers with some friends at a dinner table. And his wife made or bought one of those Potpourri and Christmas lights in a jar (remember those?) seems like all the craft stores were selling.
Well.......after I don't remember how many the thing went up in flames.......so just a word of caution when sticking a bulb (regardless of how small it is) in something cooling space needs to be considered.

Well. It is a galvanized steel junction box that goes into every home in America. I pop all the holes out so it is vented on 5 sides. Further the harness is fitted with a LED .5 bulb generating 12 lumens & no heat that I can feel.

Best,
Mark

 

[RomanyCaravan]

Venting?

Venting?

My opinion here. I think you have created a Luminaire. In its current form I see no way that UL would List It. It just has too many safety issues. The easiest things to fix are the extra holes that can't be there. I don't think they would accept the idea of the backlight behind a piece of plastic either unless that plastic was UL recognized as fire resistant. If this is intended to go into a wall so that only the surface is visible it would be in violation of NEC restrictions on putting cords inside of walls. I also don't believe that you would be allowed to just click the light inside there like that. I think it would have to be secured in some way. There may be other issues as well but don't come to mind right this second. I don't think there's anything really wrong with the basic idea but I think the implementation has major issues.

Bob:
I'm confused. It seems the extra holes are assets which increase venting. This is a junction box that is in all homes in America. I can easily not punch out these holes but why would that reduce risk? Seems it would increase it.. THe harness is affixed with a .5 LED bulb. I can feel no heat generated in this set-up, at all.

Best,
Mark

 

[RomanyCaravan]

CLass 2 Power Supply

CLass 2 Power Supply

Yeah, I THINK that if the cord / lampholder assembly is itself ALREADY listed as an assembly, you are not responsible for re-listing it. You assembly could be considered similar to a "night light cover" that clips onto an already listed night light.

That said, if what you are REALLY wanting to sell is the art part of this, you could consider finding a low voltage LED based light source for it, one that comes with a UL listed "wall wart" Class 2 power supply. Then your "fixture" becomes low voltage and not subject to needing listing.

Can you give me an example of a "wall Art" class 2 power supply? We had contemplated a usb power outlet block (like those used to charge iphones) connect to a USB cord which powers a low voltage LED night light (we found several samples on Aliexpress). Would that possibly keep us out of certification?

THanks Jraef,

Mark

 

[RomanyCaravan]

Backlit film

Backlit film

My opinion here. I think you have created a Luminaire. In its current form I see no way that UL would List It. It just has too many safety issues. The easiest things to fix are the extra holes that can't be there. I don't think they would accept the idea of the backlight behind a piece of plastic either unless that plastic was UL recognized as fire resistant. If this is intended to go into a wall so that only the surface is visible it would be in violation of NEC restrictions on putting cords inside of walls. I also don't believe that you would be allowed to just click the light inside there like that. I think it would have to be secured in some way. There may be other issues as well but don't come to mind right this second. I don't think there's anything really wrong with the basic idea but I think the implementation has major issues.

Bob:
If it makes a difference. The backlit film is sandwiched between 2 1/8" pieces of Acrylic.

Thanks,
Mark

 

[GoldDigger]

Can you give me an example of a "wall Art" class 2 power supply? We had contemplated a usb power outlet block (like those used to charge iphones) connect to a USB cord which powers a low voltage LED night light (we found several samples on Aliexpress). Would that possibly keep us out of certification?

THanks Jraef,

Mark

The phrase is "wall wart" as in a small power supply like those used for cell phone charging. It plugs directly into an AC receptacle and looks like a wart on the smooth wall.

It is UL listed and has a limited power low voltage output. It contains internal protection against output short circuits (usually not resettable!) so the output wiring is not critical.

Sent from my XT1585 using Tapatalk

 

[RomanyCaravan]

Wall Wart

Wall Wart

The phrase is "wall wart" as in a small power supply like those used for cell phone charging. It plugs directly into an AC receptacle and looks like a wart on the smooth wall.

It is UL listed and has a limited power low voltage output. It contains internal protection against output short circuits (usually not resettable!) so the output wiring is not critical.

Sent from my XT1585 using Tapatalk

Interesting... Thanks for the tip! I've learned a lot!

Best,
Mark

 

[RomanyCaravan]

Into a wall?

Into a wall?

My opinion here. I think you have created a Luminaire. In its current form I see no way that UL would List It. It just has too many safety issues. The easiest things to fix are the extra holes that can't be there. I don't think they would accept the idea of the backlight behind a piece of plastic either unless that plastic was UL recognized as fire resistant. If this is intended to go into a wall so that only the surface is visible it would be in violation of NEC restrictions on putting cords inside of walls. I also don't believe that you would be allowed to just click the light inside there like that. I think it would have to be secured in some way. There may be other issues as well but don't come to mind right this second. I don't think there's anything really wrong with the basic idea but I think the implementation has major issues.

Bob:
I appreciate the input but I don't think you've wrapped your head around what we're offering. The juction box with light and artwork composed does not go into a wall... It sits on a desk or an end table. It's very well vented (the more holes the better). I think fire retardant Acrylic UL mandate when exposed to a .5 LED bulb is a wacky thought. Just an opinion. I asked for yours and I appreciate the input but a violation of NEC restrictions is not the case here. The power cord goes in the outlet via a plug. I guess, with respect, read the post well before responding. I thank you for helping me though,

Best,
Mark

 

[kwired]

If this is not a part of premises wiring but rather a table/desk lamp or other consumer product, I don't know that NEC even applies to it.

That said the use of it in certain places may still require it to have a listing, but this is by fire officials or other codes other then NEC.

 

[hbiss]

A big trend right now seems to be "artists" making lamps and fixtures out of pipe fittings. I see this as no different. That said, I don't think I would want to have my name on anything that caused someone to be shocked or injured because of the design. It might not be apparent to you, but zip cord can be damaged or that bulb could break (just as a for instance) causing the metallic box to become energized. That's some of the things UL looks for when you submit the product for approval. It's why it was suggested to use a low voltage wall wart with a LV line cord and a LV LED lamp.

You might think you have a great product until someone sues you and if that happens a UL or other NRTL listing will go a long way.

-Hal

 

[Jraef]

A big trend right now seems to be "artists" making lamps and fixtures out of pipe fittings. I see this as no different. That said, I don't think I would want to have my name on anything that caused someone to be shocked or injured because of the design. It might not be apparent to you, but zip cord can be damaged or that bulb could break (just as a for instance) causing the metallic box to become energized. That's some of the things UL looks for when you submit the product for approval. It's why it was suggested to use a low voltage wall wart with a LV line cord and a LV LED lamp.

You might think you have a great product until someone sues you and if that happens a UL or other NRTL listing will go a long way.

-Hal

Bingo, that's exactly the issue. The NEC is not a concern if not part of premise wiring, your product is more like an appliance. Any one of us can make a one-off lamp for our own use at our own risk. Where you get in trouble is when you commercialize something. Once you sell it for a profit, you incur responsibilities for its use and the safety of users. That's what UL listing is about to a certain extent.

I stumbled across that zip-cord lamp on a crafting site and it says "UL rated". You need to understand that this is often a clue as to it being fraudulent or at least suspicious, because UL uses VERY specific terms with specific meanings and I don't think "rated" is one of them. It's a trick used by unscrupulous suppliers to sell their products to unwary consumers.
http://www.ul.com/marks/ul-listing-...ing-guidelines/specific-guidelines-and-rules/

 

[RomanyCaravan]

Bingo, that's exactly the issue. The NEC is not a concern if not part of premise wiring, your product is more like an appliance. Any one of us can make a one-off lamp for our own use at our own risk. Where you get in trouble is when you commercialize something. Once you sell it for a profit, you incur responsibilities for its use and the safety of users. That's what UL listing is about to a certain extent.

I stumbled across that zip-cord lamp on a crafting site and it says "UL rated". You need to understand that this is often a clue as to it being fraudulent or at least suspicious, because UL uses VERY specific terms with specific meanings and I don't think "rated" is one of them. It's a trick used by unscrupulous suppliers to sell their products to unwary consumers.
http://www.ul.com/marks/ul-listing-...ing-guidelines/specific-guidelines-and-rules/

Hi Jraef:

I like the idea of a low voltage alternative. Why does using a low voltage wall wart with a LV line cord and a LV LED lamp potentially make my init safer? Attached is a photo of a wiring alternative I've considered. What do you all think? I'm just a newbie here

2.6W 5V 4.9ft/1.5M magnetic/tape Metal base 6LED USB light lamp With switch AB6

I really only need about 15 Lumens to light the box up properly. Please take a look when you have a chance. It could plug into a wall charger similar to those used for phones... Am I on the right track here?

Many Thanks,
Mark

 

[petersonra]

Now that I have a better feel for what it actually is...

Since it is not going inside a wall, I withdraw my objections on those points.

I am inclined to agree with the poster who suggested it is not subject to the NEC since it is not part of the installation.

I still think it is likely to require UL listing as a practical matter if you want to sell it widely. Few stores will sell an unlisted electrical product.

I think in its current incarnation it has several issues that would prevent listing. One is the holes. Generally electrical devices are allowed to have ventilation openings and be listed but there are size limits to the openings. Something you can get a small finger in is too big. I think the general rule is something like 0.17" or so. [Please do not quote that number as authoritative though. It might be a little off].

The other problem I see with listing is that the metal box encloses electrical wiring and thus would require a ground wire.

Personally, if I was going to design something like this and wanted to list it I would use a plastic box of UL recognized material for both flame resistance and insulation characteristics. That would greatly simplify listing. I would also agree with the posters who suggested a class 2 power supply. That greatly simplifies listing as well.

If you decide to try and sell an unlisted product I think you are limiting the potential sales but getting it listed is not cheap either. I also think you will find that getting product liability insurance for an unlisted electrical product is all but impossible.