Q & A: Everything to do with UL Marks

Outsourcing the manufacture and printing of ‘Finished Product’ labels containing a UL Mark.

- Everything you need to know!


The process for putting a UL Mark onto a ‘combined label’ is incredibly complicated, and to help our customers we have compiled this guide in a question and answer format, which if you read from start to finish, should tell you everything you need to know.

Unfortunately we cannot act on your behalf because the UL Mark approval has to be directly between you (the UL Certificate holder) and the UL Label Centre. As you read on, you will understand why. However, as part of our free service to customers, we understand UL compliance and can guide you through the process. Please don’t struggle with the complexities, call us, email us, use live chat or fill a form and we will supply you with a conforming label and help you navigate the UL Marking process.

 
What is a Finished Product Label?

Once your product has received certification you will need to display the correct UL Mark on your products as evidence that the product has received certification. The label can be separate and only carry the UL Mark but it is usually more cost-effective to add it into the design of another label on your product.

 
What is a ‘Combined Label Design’?

UL refers to a finished product label that incorporates one of its UL Marks into a design that contains other information as a ‘combined label design’.


Where can I buy a ‘Combined Label’?

 ‘Combined labels’ can only be purchased from a label supplier approved by UL under the PGAA Approved Supplier Program.

Why does the label manufacturer need to be approved and have an active UL file under PGAA?

PGAA approved label manufacturers know the approval procedures required for different UL ‘Follow-up’ services and they understand which documents they need to hold on file to complete the UL audit trail for authorised reproduction of the UL Mark onto a label.

What is the UL File Number for CILS International?

CILS International (Computer Imprintable Label Systems Ltd.) is found under file LP4579 on the UL online directory under the category PGAA (Approved Label Suppliers)

Does PGAA approval mean that the label material is approved?

The fact that a label printer/manufacturer is found under PGAA only means that it is authorised to reproduce a UL Mark onto a label. It does not mean that the label construction is approved.

How do I know if the label itself needs to be UL approved?

UL states that finished product labels need to be appropriately durable, permanently affixed and legible for the life of the product. UL does not insist that finished product labels carrying the UL Mark or be made from UL approved materials. However, they do state that if the UL mark is no longer legible or the label has fallen off, the product is no longer UL approved.

Do finished product labels carrying the UL Mark need to be made from UL approved labels?

Generally speaking, if the other information on a combined label is important to the use of the product, e.g. instructions, warnings, rating info, etc. then the label and its printing may need to be approved under UL969 (Labels and Labelling Systems) because UL may consider this label to be a component part of the product. Additional tests to those found in UL969 may also be required e.g. for fire extinguisher systems.

What is the UL Follow-up Service (FUS)?

UL operates a ‘Follow-up Service’ (FUS) to audit production facilities and products to determine ongoing compliance with UL requirements. There are two types, Type ‘R’ and Type ‘L’ (Source: https://www.ul.com/offerings/follow-up-services)

What is the UL Type ‘R’ Follow-up Service?

This service is primarily intended for electrical appliances, components and other products. An audit schedule is set with the UL customer dependant on the product group and has a minimum of 4 inspections per year. Because the inspection schedule is known and announced, the UL Label Centre does not need to be involved with every order for labels once the UL Mark is approved.

What is the UL Type ‘L’ Follow-up Service?

This Follow-up Service is primarily intended for life safety products and products where the manufacturing process is susceptible to higher degrees of variability. The number of UL inspections is dependent on the number of UL Marks used i.e. products manufactured/labelled. Therefore, UL must be involved with every order of labels that is placed, in order that they have a count of the number of products labelled and can then set its unannounced inspection schedule accordingly.

(Source: https://legacy-uploads.ul.com/wp-content/uploads/2014/05/FUStart_English.pdf)

Why does the type of 'Follow-up Service' influence the approval of the UL Mark?

For the Type ‘L’ Follow-up Service, UL must be involved with every order for combined labels so they know how many products are being labelled. When you place your label order with your PGAA supplier, you must notify the UL Label Centre simultaneously. The PGAA approved supplier can only manufacture your labels once they have received the authorisation to do so from the UL Label Centre.

For the ‘R’ type Follow-up service UL needs to be involved with the initial UL Mark approval but once approved, does not need to be involved with re-orders.

Does UL need to approve the UL mark on a label?

Irrespective of the type of service you have with UL, you will need to submit your label design to your local UL Label Centre for approval, before your labels are manufactured for the first time.

Once approved, can any label printer/manufacturer print my labels?

You can only outsource the printing of your labels to a label manufacturer found under the PGAA approved suppliers list.

Who is the UL Label Centre?

The UL Label Centre is the division of UL responsible for the correct representation of the UL Mark on products and marketing/promotional materials for your products

Where is my local UL Label Centre?

Canada, China, Europe (Italy), Japan, South Korea, Latin America (Mexico), Taiwan, United States (Illinois).

How often is the UL Label Centre involved in my label design?

Type ‘R’ FUS labels need only be approved by your local UL Label Centre once. Documentation will be provided to you for your PGAA approved supplier to keep on file so that they can reproduce labels for you without further involvement from your local UL Label Centre.

Type ‘L’ FUS labels will have the label design approved in the same way as type ‘R’, however, every time you re-order labels from your PGAA approved supplier, you will need to advise your local UL Label Centre at the same time you place an order with your PGAA approved supplier, so that UL has a record of how many products have been labelled.

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