John,

Since product B is an accessory for use with UL Listed Product A, then I
would submit product B to UL for accessory Listing for use with Product A.
This is a very wise thing to do, especially if there were any questions by
local inspectors or by the judge in case of a product liabilility lawsuit. 

Accessory Listing product B should be no problem at all. UL might ask you to
throw in an instruction leaflet on how to install accessory B properly and
that this must be done by qualified personnel. 

In regards to the UL Listing Mark, it is the same as the one you have on the
product A except for the element ACCESSORY LISTED instead of LISTED adjacent
to the UL logo. Being a small unit, UL also allows you to put all the
required markings and UL logo on the packaging rather than on the product.


Regards,


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PETER S. MERGUERIAN
Technical Director
I.T.L. (Product Testing) Ltd.
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-----Original Message-----
From: John Juhasz [mailto:john.juh...@ge-interlogix.com]
Sent: Monday, September 16, 2002 5:25 PM
To: 'emc-p...@ieee.org'
Subject: Add-On Printed Circuit



Colleagues,

I am seeking your input.

Manufacturer A sells a complete, fully approved  (CE, FCC Part 15, UL, etc)
product (product A)
Manufacturer B makes a device (product B) that will plug into a connector in
product A
(actually inside product A's enclosure - like a 'daughter' module) as a
value added feature. 
There are no external interfaces on product B, and it is not accessible
unless product A is totally dismantled. Product B is intended/sold only for
use with product A,
and is otherwise useless.
The two products are sold independent of each other by the manufacturers to
'dealer/installers'. 
When the dealer/installer sells/installs product A, he can offer product B
as an option.

What are the regulatory requirements/manufacturer's responsibilities for
product B?
(est. 2-3 inches square, UL 94V-0 printed circuit board, tens of mA 12V DC,
no external interfaces.
On-board clock). 

Thoughts?

John A. Juhasz

GE Interlogix
Fiber Options Div.
Bohemia, NY 


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