UL requirements for a simulator

CE is tougher because it includes a lot of stuff that does not directly affect personal and fire safety.

UL is really tougher because you cannot self-certify and the testing is very stringent. Have you also gotten your FCC? You'll need that too. FCC is required by law (I'm assuming you're in the US)

Step one: Contact UL for a quote. Your whole machine needs testing, and you'll have to ask them to help you decide which standard applies (probably just a general safety standard). It's good that you used all listed/recognized components. Here's the place to go:


Prepare yourself for sticker shock, but don't despair.

Step two: Contact UL's competitors. ETL, TUV, CSA, and METLabs are ones I've used. There are others. There's an entire list of NRTLs (Nationally Recognized Testing Labs) available from OSHA:


Get quotes on testing to the equivalent standards. They can test to UL standards, and you can then sticker your product with (for example) ETL certified to UL Standard XXXX, with a nice looking logo. My refrigerator has CSA in it, not UL. My washer and dryer have ETL. Lots of people aren't using UL anymore because of cost and speed.

Step three: Choose the lab that gives you the best combination of price and turnaround time. Then negotiate the FCC testing with them as an add-on before you sign up, maybe you can get some money knocked off the package.

That's how I'd go at it. Good luck!

Good on ya,

Goober Dave

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Hi Gobber
Many thanks for the above, very helpful

We are based in the UK so do we need an FCC too (whatever that is )?

Is it OK to start selling product into the US stating "awaiting UL certification" or "UL certification applied for" - we should have CE self certification by then anyway?

The link i attached above is of a company based in the US. The only information i can see about CE or UL on their web site is "all motors, drives and amplifiers are CE and UL marked". I am pretty sure they are not CE or UL certified as a whole machine and yet their focus on sales for home use.

How can this be and what are the implications to them of doing this as they have been selling for years?

What are the implications to us as an importer not having UL initially

Happy to cover the machine in stickers but as with all businesses we need to start generating income without getting too consumed on certifcation restrictions. Our intention is CE and UL cert and any other requirements

Yes, if you're selling into US you will need FCC since your product obviously has processing power in it. There are some exemptions in that set of rules, but I doubt that you meet them. I don't have mine handy right here.

"UL applied for" doesn't work, and would probably get you some nasty correspondence from UL if they found out.

However, your second post raises a question in my mind. I'm now imagining (pardon the gross guess) a custom box you've made that contains a computer or two, a display, a hydraulic system or some other mechanicals, and a custom control panel to interface the hydraulics with the computers. If your computers, displays, and mechanicals(s) are all unmodified-out-of-the-box UL-listed products that simply plug in to an appropriate outlet, then they are not subject to further investigation by UL. If you've modified them, the UL is void.

If your custom control panel and controls are all operating below 40V, they are not subject to investigation by UL either, as long as the power supply feeding them is listed.

The items subject to FCC are the things that may radiate (computers, displays). They will already have FCC logos on them.

If your custom control panel has processors in it, that might be the only thing in need of FCC evaluation.

In other words, if you could ship this simulator to a customer in pieces and have him plug each item in individually, would they all be listed items? And would all of the potential radiators already have FCC certification? If so, and all you're doing electrically is gathering the power supply cords into a single point, you may not need anything done as a whole. I think that you could then employ the "all parts listed" marketing thing.

Anything you've done custom with higher voltages inside may need attention, though.

I'd wait to hear from others on the forum. I know my way around UL and FCC, but not so much with consumer goods.

Interesting!



Good on ya,

Goober Dave

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