NRTL / UL listing: when a US safety mark is required

Hugues Orgitelloupdated 7 Oct 202615 min read

An NRTL is a private organisation that OSHA has recognised, under 29 CFR 1910.7, to test and certify specific products against specific safety standards. OSHA requires workplace electrical equipment to be "approved", and NRTL certification is the main route to that status; state and local electrical codes, and some state laws, then extend the use of listing well beyond the workplace. FCC authorisation covers the radio side and says nothing about shock, fire or stored energy, so a device can hold a valid FCC ID and still have no recognised safety evaluation. This guide sets out what the regulations actually say: what "approved", "listed" and "labeled" mean in 29 CFR 1910.399, what the NRTL recognition covers and does not cover, where the National Electrical Code, state law and the CPSC come in, which UL editions are current, and how a CB Scheme report can feed the US listing.

TL;DR:

• NRTL status is an OSHA recognition (29 CFR 1910.7 and Appendix A), per standard and per site, valid five years. It is not accreditation and not a product endorsement.
• 29 CFR 1910.303(a) accepts workplace electrical equipment only if "approved". NRTL certification is one of three routes in 1910.399; the other two cover equipment no NRTL handles and custom-made equipment.
• OSHA states that it does not require manufacturers or suppliers to certify. Codes adopted by states and cities, and state laws such as N.C. Gen. Stat. 66-25, are where listing reaches the product on sale.
• Current editions: UL 62368-1 edition 4 (July 31, 2025), UL 61010-1 edition 3 revised November 15, 2024, UL 60335-1 edition 7 (December 11, 2025).
• A CB report is issued by an IECEE NCB (tests by its CBTL); an NRTL can use it and assess the US national differences.

Two tracks: radio and safety

The United States has no single product clearance like the European CE marking. Radio and product safety sit under different legal instruments and different organisations.

Concern	Mechanism	Legal basis	Mark or identifier
Radio and EMC	FCC equipment authorisation (certification or SDoC)	47 CFR (FCC rules)	FCC ID or SDoC compliance statement
Electrical safety in workplaces	NRTL certification ("approved" equipment)	29 CFR 1910.303 and 1910.399 (OSHA)	Registered certification mark of the NRTL
Electrical safety in installations	Listing or labeling accepted by the authority having jurisdiction	NFPA 70 (NEC) as adopted by states and cities	Listing mark
Consumer product safety	Mandatory rules for specific products, recalls	Consumer Product Safety Act, enforced by the CPSC	Certificate for products subject to a rule

The FCC pillar covers the radio side. This guide is about the other rows. In Europe, Directive 2014/53/EU (RED) covers radio, EMC and safety in one Declaration of Conformity signed by the manufacturer. In the US, the safety part runs through third-party certification, and the obligation to use it sits mostly on the employer and the installation, not on the product placed on the market.

What 29 CFR 1910 actually requires

OSHA electrical rules for general industry are in Subpart S of 29 CFR 1910. Section 1910.303(a) reads: "The conductors and equipment required or permitted by this subpart shall be acceptable only if approved, as defined in § 1910.399." The definitions then chain together.

Term (29 CFR 1910.399)	What the text says
Approved	"Acceptable to the authority enforcing this subpart", which is the Assistant Secretary of Labor for Occupational Safety and Health
Acceptable, route (1)	"Accepted, or certified, or listed, or labeled, or otherwise determined to be safe" by an NRTL recognised under § 1910.7
Acceptable, route (2)	For "a kind that no nationally recognized testing laboratory" handles: inspected or tested by another federal agency, or by a state, municipal or other local authority enforcing the NEC, and found in compliance
Acceptable, route (3)	For custom-made equipment designed and fabricated for a particular customer: determined safe by its manufacturer on the basis of test data that the employer keeps and makes available to OSHA
Listed	Of a kind mentioned in a list published by a nationally recognized laboratory "that makes periodic inspection of the production of such equipment", stating that it meets nationally recognized standards or was tested and found safe for use in a specified manner
Labeled	Bears a label, symbol or other identifying mark of an NRTL that makes periodic inspections of production, indicating compliance with nationally recognized standards
Accepted	An installation inspected and found by an NRTL to conform to specified plans or to procedures of applicable codes

Two consequences matter for a manufacturer. First, the obligation is the employer's: the OSHA FAQ says its authority is limited to employers and that "OSHA does not require manufacturers or suppliers, as applicable, to have the products they manufacture or supply certified by an NRTL." Your customer, if it is an employer, is the one who must use approved equipment. Second, NRTL certification is the route that works for standard products; routes (2) and (3) exist but are narrow. The OSHA FAQ also counts requirements for NRTL testing and certification across 39 product types in its standards.

1910.303(b)(2) adds that listed or labeled equipment "shall be installed and used in accordance with any instructions included in the listing or labeling", so the conditions in the listing travel with the product.

What NRTL recognition is

29 CFR 1910.7(b) defines an NRTL as an organisation "recognized by OSHA in accordance with appendix A of this section" that tests for safety and lists, labels or accepts equipment, and that meets four criteria:

1910.7(b) criterion	Content
(1) Capability	Testing equipment and facilities, trained staff, written test procedures, calibration and quality control, for each item it lists, labels or accepts
(2) Controls and services	Control procedures to identify listed and labeled products, inspection of the production run at factories, field inspections to monitor the use of its mark
(3) Independence	Completely independent of the employers using the equipment and of the manufacturers or vendors of the equipment tested
(4) Procedures	Creditable, objective findings, and a fair system for complaints and disputes

Appendix A sets the process: application, evaluation of the product evaluation and control programs and of the testing facilities, a recognition letter that states the scope, and a period of recognition: "The recognition by OSHA of each NRTL will be valid for five years, unless terminated before the expiration of the period." OSHA charges fees for applications, renewals and site audits under 1910.7(f).

What recognition is not, in the words of OSHA: it is "an acknowledgment that an organization has necessary qualifications to perform safety testing and certification of the specific products covered within its scope of recognition", and "OSHA's recognition of an NRTL is not an endorsement of the equipment certified by the NRTL." OSHA does not test or approve individual products. The test standards themselves must meet 1910.7(c): recognised in the US as providing an adequate level of safety and developed by a consensus process, or designated as an ANSI safety product standard or an ASTM test standard.

Which organisations are NRTLs today

The OSHA current list, consulted on October 7, 2026, names 21 organisations:

NRTL (as listed by OSHA)	Short name
Bay Area Compliance Laboratories	BACL
Bureau Veritas Consumer Products Services, Inc.	BVCPS
CSA Group Testing and Certification Inc.	CSA
DEKRA Certification, Inc.	DEKRA
Element Materials Technology Portland, Evergreen Inc.	Element
Eurofins Electrical and Electronic Testing NA, Inc.	Eurofins/MET
FM Approvals	FM
International Association of Plumbing and Mechanical Officials EGS	IAPMO
Intertek Testing Services NA, Inc.	Intertek/ITS
Japan Electrical Safety & Environment Technology Laboratories	JET
LabTest Certification Inc.	LC
Nemko North America, Inc.	NNA
NSF International	NSF
QAI Laboratories, LTD	QAI
QPS Evaluation Services Inc.	QPS
SGS North America, Inc.	SGS
SolarPTL, LLC	SolarPTL
Southwest Research Institute	SWRI
TUV Rheinland of North America, Inc.	TUV
TÜV SÜD America Inc.	TÜVSÜD
UL LLC	UL

Each entry links to a scope page listing the standards and the recognised sites. That page, not the logo, is what you check. The OSHA FAQ states that an NRTL "may only certify products to the specific product safety test standards included in its scope of recognition", and the certification must come from one of its sites that OSHA has recognised. On equivalence, OSHA "considers NRTLs recognized for the same product safety test standard to be capable of testing to, and certifying under, that standard". There is no ranking between NRTLs, but the equivalence is standard by standard.

The OSHA program page adds that each NRTL "uses its own unique registered certification mark(s)", and that a mark signifies NRTL certification "if the certification is done under the NRTL program". The logo alone does not tell you the standard or whether the certification was done under the program, so ask for the certificate.

Listed, Recognized Component, Classified

These are UL program names, described on the UL Marks Hub; other NRTLs use their own terms.

• Listed: a complete product evaluated to its end-product standard. This is what a code official normally means by a listing.
• Recognized Component: a part evaluated for use inside another product under stated conditions of acceptability (the backwards "RU" mark). It does not make the finished product listed.
• Classified: a product evaluated for specific properties or hazards, or for use under specific conditions, rather than against a full product standard.

A UL-marked power supply inside your product reduces the work on that block, but the end product still needs its own evaluation.

UL standards for electronics, with current editions

NRTLs certify to US standards that meet 1910.7(c). For electronics most are US adoptions of an IEC standard with national differences.

Product family	US standard	Current edition in the UL catalogue	IEC base
Audio/video, information and communication technology equipment	UL 62368-1	Edition 4, July 31, 2025 (ANSI approval same day); edition 3 archived	IEC 62368-1 edition 4 (May 2023)
Measurement, control and laboratory equipment	UL 61010-1	Edition 3, May 11, 2012, latest revision November 15, 2024	IEC 61010-1
Household and similar appliances	UL 60335-1	Edition 7, December 11, 2025; edition 6 still shown as active	IEC 60335-1 edition 6.0 (September 2020)

UL 62368-1 edition 4 is a bi-national standard with CSA C22.2 No. 62368-1, and its US national differences refer to the NEC and to the Canadian Electrical Code. The move from UL 60950-1 and UL 60065 to UL 62368-1 mirrors the European move to EN 62368-1; the LVD still cites EN 62368-1:2014 + AC:2015. For the engineering logic see the IEC 62368-1 guide, and for appliances the EN 60335 household appliances guide.

Before you start, ask the NRTL which edition it will certify to, and check on the OSHA scope page that the standard (and edition, where stated) is inside its recognition.

Factory follow-up is part of the definition

A listing is not a one-time pass. 1910.7(b)(2) requires the NRTL to provide, "to the extent needed", control procedures for identifying listed and labeled products, inspection of "the run of production of such items at factories", and field inspections of the use of its mark. The 1910.399 definitions of "listed" and "labeled" both require a laboratory that makes periodic inspection of production. The frequency and form of these inspections are set by each NRTL in its own program.

In practice the listing is tied to the construction described in the certification file. Changing a safety-critical component, an enclosure material or a spacing near hazardous voltage is something to raise with the NRTL before production, not after an inspection finds it.

When a listing is actually required

The obligation comes from several places, and each binds a different person.

Source	Who it binds	What it requires	Text
OSHA Subpart S	Employers, for equipment used by employees	Equipment must be "approved"; NRTL certification is the standard route	29 CFR 1910.303(a), 1910.399
National Electrical Code (NFPA 70)	Installers and owners where the code is adopted	Approval by the authority having jurisdiction; listing is the usual evidence; listing by qualified electrical testing laboratories (110.3(C))	NEC as adopted locally
State product laws	Anyone selling in the state	Example: North Carolina requires electrical products to be evaluated by a qualified testing laboratory before sale	N.C. Gen. Stat. 66-23 and 66-25
State electrical rules	Installations in the state	Example: Washington requires equipment to conform to recognised standards, be listed, or be field evaluated	Chapter 296-46B WAC
CPSC	Manufacturers and importers of consumer products	Certificates only for products subject to a consumer product safety rule; no NRTL requirement	16 CFR 1110
Contracts	Parties to the contract	Whatever the purchase terms say	The contract

The NEC and state adoption

The NEC is a model code published by NFPA; it binds only where a state or city adopts it, often with amendments, and on its own timetable. Washington, for example, adopts the 2026 edition (NFPA 70-2026) effective December 31, 2026, replacing the 2023 edition. NEC 90.7, quoted by the North Carolina Office of State Fire Marshal, states that factory-installed internal wiring or the construction of equipment need not be inspected at installation "if the equipment has been listed by a qualified electrical testing laboratory". For installed equipment (fixed luminaires, distribution equipment, chargers, control panels), listing is how an inspector accepts the product without opening it.

North Carolina: a state law that acts on sale

The North Carolina interpretation of September 28, 2023 quotes N.C. Gen. Stat. 66-25(a): electrical materials, devices, appliances and equipment shall be evaluated for safety and suitability, the evaluation "shall be conducted in accordance with nationally recognized standards and shall be conducted by a qualified testing laboratory". Article 4 of Chapter 66 applies before "selling, offering for sale" such products in the state, and the State Electrical Division approves the qualified laboratories. This is a product law, not a workplace rule. Check the rules of each state you ship to.

The CPSC

The Consumer Product Safety Commission enforces consumer product safety rules and handles recalls. Its General Certificate of Conformity applies to certain general-use (non-children's) products that are subject to a consumer product safety rule, and the CPSC states that "third-party laboratory testing is not a requirement for general-use products". Since July 8, 2026, importers of products subject to the certification requirement must eFile certificate data at entry (January 8, 2027 for foreign trade zone entries). None of this is an NRTL listing, and an NRTL listing does not replace a CPSC certificate where a rule applies.

Feeding a US listing from a CB Scheme report

The IECEE CB Scheme is the international system for mutual acceptance of safety test reports and certificates. A National Certification Body (NCB) issues the CB Test Certificate and CB Test Report against an IEC standard; the tests are performed by a CB Testing Laboratory (CBTL) attached to that NCB. The IECEE member-bodies page lists the United States, through the US National Committee of the IECEE, with its own National Certification Bodies and CB Testing Laboratories.

An NRTL that recognises the standard can take the CB package as the basis and assess the US national differences to the UL standard, instead of repeating the shared IEC tests.

Step	Without a CB report	With a CB report
IEC base requirements	Tested as part of the UL project	Covered by the CB Test Report, reviewed by the NRTL
US national differences	Tested	Tested
Edition match	Not an issue	Check that the IEC edition in the CB report matches the edition the UL standard adopts (for UL 62368-1 edition 4, IEC 62368-1 edition 4)
Who issues the US listing	The NRTL	The NRTL, under its own program
Factory follow-up	Required	Required

Ask the CBTL to include the US national differences at the outset; the IECEE says the detailed differences are available through your NCB.

How this differs from EU self-declaration

Aspect	EU, LVD or RED safety	US, NRTL listing
Who attests	Manufacturer, in its own Declaration of Conformity	The NRTL, by listing or labeling
Third party	Not required for most electronics	The certification is by definition third-party
Mark	CE marking	Registered certification mark of the NRTL
Production surveillance	Only under some modules	Part of the NRTL definition (1910.7(b)(2))
Who carries the obligation	Manufacturer placing on the market	Employer (OSHA), installation (NEC), seller in some states

The FCC side does offer self-declaration for some devices (SDoC), but that is radio only. OSHA states that the CE mark "is unrelated to the requirements for product safety in the United States".

Claims the texts contradict

Common claim	What the text says
"OSHA accredits NRTLs"	NRTL status is a recognition under 1910.7 and Appendix A, per standard and per site, valid five years. OSHA calls it an acknowledgment of qualifications and not an endorsement of products.
"OSHA approved means NRTL-certified, full stop"	1910.399 "acceptable" has three routes: NRTL; for a kind no NRTL handles, inspection by a federal, state or local authority enforcing the NEC; custom-made equipment with manufacturer test data kept by the employer.
"Any UL, ETL or CSA mark is equivalent"	Equivalence holds for NRTLs recognised for the same standard. A mark counts as NRTL certification only if it was issued under the program, within scope, from a recognised site.
"No law requires a listing for products on sale"	OSHA does not bind manufacturers, but North Carolina law requires evaluation by a qualified testing laboratory before sale in the state.
"The CB report is produced by an accredited laboratory"	The CB Test Certificate and Report are issued by an IECEE NCB; the tests are done by its CBTL. ISO/IEC 17025 accreditation alone does not make a laboratory a CBTL.
"An NRTL is the US recognition layer on top of laboratory accreditation"	OSHA evaluates NRTLs against its own 1910.7 criteria (capability, controls, independence, procedures).
"UL 62368-1 is the 2019 edition 3"	Edition 4 is dated July 31, 2025 and adopts IEC 62368-1 edition 4; edition 3 is archived in the UL catalogue.
"The CPSC requires third-party safety certification for electronics"	The CPSC states that third-party testing is not required for general-use products; certificates apply only to products subject to a rule.
"A CE mark is accepted in the US for safety"	OSHA says the CE mark is unrelated to US product safety requirements.

Common pitfalls

• Assuming the FCC ID is enough. It covers radio only.
• Trusting a logo instead of the scope. Check the OSHA scope page for the standard and the site that issued the certificate.
• Confusing Recognized Component with Listed. A recognised internal power supply does not list the end product.
• Changing safety-critical parts without telling the NRTL. The listing is tied to the construction in the file, and production is inspected against it.
• Mixing editions. A CB report on an older IEC edition may not match the edition the UL standard now adopts.
• Forgetting state rules. The NEC edition and amendments, and laws such as North Carolina's, differ by state.
• Ignoring Canada. Canada has its own certification system; UL 62368-1 and UL 60335-1 are bi-national texts, but a US listing is not automatically a Canadian certification.

A worked example

Case: a mains-powered IoT gateway with Wi-Fi, sold to US companies and installed in their equipment rooms.

The radio side goes through FCC equipment authorisation, see the FCC pillar. Because the buyers are employers and the gateway is electrical equipment used in their workplace, 1910.303(a) requires it to be approved, and NRTL certification is the practical route. The applicable standard is UL 62368-1 edition 4.

The efficient route: test to IEC 62368-1 edition 4 at a CBTL, get the CB Test Certificate and Report from the NCB with the US national differences in scope, then submit to an NRTL whose OSHA scope includes UL 62368-1, and plan for factory follow-up. If the gateway will be shipped to North Carolina, the state law applies on sale as well. The same CB report also supports the European DoC.

See also

• Conformity assessment bodies and accreditation
• CB Scheme (IECEE): global safety via one report
• FCC ID, Grantee Code & TCB: equipment authorization
• California Prop 65 warnings for electronics
• ISED Canada radio certification

Working on planning a US NRTL safety listing and reusing a CB Scheme report across markets for a real product? AESTECHNO can audit your design and certification plan. Get in touch

Sources & references

1. Nationally Recognized Testing Laboratory (NRTL) Program, OSHA www.osha.gov/nationally-recognized-testing-laboratory-program
2. Current list of NRTLs and their scopes of recognition, OSHA www.osha.gov/nationally-recognized-testing-laboratory-program/current-list-of-nrtls
3. NRTL Program frequently asked questions, OSHA www.osha.gov/nationally-recognized-testing-laboratory-program/frequently-asked-questions
4. 29 CFR 1910.7, Definition and requirements for a nationally recognized testing laboratory (with Appendix A), eCFR www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-A/section-1910.7
5. 29 CFR 1910.303, General requirements (electrical, approval), eCFR www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-S/section-1910.303
6. 29 CFR 1910.399, Definitions (acceptable, approved, listed, labeled), eCFR www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-S/section-1910.399
7. UL 62368-1 edition 4 (July 31, 2025), UL Standards & Engagement www.shopulstandards.com/ProductDetail.aspx?productId=UL62368-1_4_S_20250731
8. UL 61010-1 edition 3 (revision November 15, 2024), UL Standards & Engagement www.shopulstandards.com/ProductDetail.aspx?productId=UL61010-1
9. UL 60335-1 edition 7 (December 11, 2025), UL Standards & Engagement www.shopulstandards.com/ProductDetail.aspx?productId=UL60335-1_7_S_20251211
10. NFPA 70, National Electrical Code (code development page), NFPA www.nfpa.org/codes-and-standards/nfpa-70-standard-development/70
11. Qualified testing laboratories, interpretation of NEC 90.7 and 110.3 and N.C. Gen. Stat. 66-25 (September 28, 2023), North Carolina Office of State Fire Marshal www.ncosfm.gov/electrical/section-907-qualified-testing-laboratories/open
12. Chapter 296-46B WAC amendments adopting NFPA 70-2026 from December 31, 2026, Washington State Department of Labor & Industries www.lni.wa.gov/licensing-permits/_docs/2508-Proposal-Adopted-Standards.pdf
13. General Certificate of Conformity (general-use products), CPSC www.cpsc.gov/Business--Manufacturing/Testing-Certification/General-Certificate-of-Conformity
14. Update: Certificates of Compliance and eFiling, CPSC www.cpsc.gov/Business--Manufacturing/Business-Education/Business-Guidance/Certificates
15. What is the IECEE CB scheme?, IECEE www.iecee.org/who-we-are/cb-scheme
16. IECEE member bodies (NCB and CBTL counts per country), IECEE www.iecee.org/members/member-bodies
17. UL Solutions Marks and Label Hub, Listing and Classification marks, UL Solutions markshub.ul.com/
18. Intertek ETL Listed Mark, Intertek www.intertek.com/marks/etl/
19. CSA Group product testing and certification, CSA Group www.csagroup.org/testing-certification/