Re: [PSES] UL Listing of Computer Keyboard
Hi Richard, Most useful, thank you for the email :) All the best James Richard Nute wrote > > >Hi James: > > > >Some additional information in response to your conclusions: > > > >* NRTL approval legally required for selling in the USA? No. > > > >There is no Federal law, but city, county, and state laws require NRTL. For >example (but not limited to), City of Chicago, County of Los Angeles, and >State of Oregon all require NRTL certification of electrical products. All >consumer products, products used in schools, and most non-consumer products. > > > >* NRTL / UL approval expected? Highly likely. > > > >Expected by whom? Ordinary consumers do not look for the certification mark. >However, many (most) retailers (especially those operating in several states) >will only sell NRTL-certified products both to protect themselves from >liability in case of an injury, and to comply with laws (as described above). > > > >* NRTL approval required for use in the workplace? Yes, not legally >required but market expectation? Or is it a legal requirement? > > > >Yes, NRTL certification is required (by OSHA) for the workplace. Note that >many workplaces include home appliances (such as kitchen appliances) and >computers. These need to be NRTL-certified as these workplaces are subject to >OSHA. > > > >* Standard used: UL 62368-1 > > > >Not necessarily. Depends on the product. > > > >The best strategy is to have all products, including low-voltage and limited >power products, certified by a NRTL. Then, there is no question of compliance >with laws and customer demand. > > > >Having said that, I just looked at my new (and an older) Bluetooth mouse: no >certifications! Same for my TV remotes. However, an older wireless mouse >(same manufacturer) has NRTL certification. Two of three keyboards have NRTL >certifications. My tablet is not certified, but my laptop and (low voltage) >docking station are certified. As an ordinary consumer, I did not look for >the certification mark on any of my electrical products. (I did look for the >certification mark on my mains outlets devices that included USB charging >outlets.) > > > >Best regards, > >Rich > > > > > > > - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] UL Listing of Computer Keyboard
Hi James: Some additional information in response to your conclusions: * NRTL approval legally required for selling in the USA? No. There is no Federal law, but city, county, and state laws require NRTL. For example (but not limited to), City of Chicago, County of Los Angeles, and State of Oregon all require NRTL certification of electrical products. All consumer products, products used in schools, and most non-consumer products. * NRTL / UL approval expected? Highly likely. Expected by whom? Ordinary consumers do not look for the certification mark. However, many (most) retailers (especially those operating in several states) will only sell NRTL-certified products both to protect themselves from liability in case of an injury, and to comply with laws (as described above). * NRTL approval required for use in the workplace? Yes, not legally required but market expectation? Or is it a legal requirement? Yes, NRTL certification is required (by OSHA) for the workplace. Note that many workplaces include home appliances (such as kitchen appliances) and computers. These need to be NRTL-certified as these workplaces are subject to OSHA. * Standard used: UL 62368-1 Not necessarily. Depends on the product. The best strategy is to have all products, including low-voltage and limited power products, certified by a NRTL. Then, there is no question of compliance with laws and customer demand. Having said that, I just looked at my new (and an older) Bluetooth mouse: no certifications! Same for my TV remotes. However, an older wireless mouse (same manufacturer) has NRTL certification. Two of three keyboards have NRTL certifications. My tablet is not certified, but my laptop and (low voltage) docking station are certified. As an ordinary consumer, I did not look for the certification mark on any of my electrical products. (I did look for the certification mark on my mains outlets devices that included USB charging outlets.) Best regards, Rich - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] UL Listing of Computer Keyboard
Again many thanks to everyone who has replied, I’ve found the responses very useful. All the best James From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org> Sent: 19 June 2018 16:07 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard NRTL approval is not a legal requirement to sell a product in the United States. There is no national legal requirement for many types of consumer products. Many jurisdictions have adopted NFPA 70, the National Electrical Code, which requires products either to be Listed by an NRTL or to be approved by the local inspector. This creates a de facto NRTL requirement for most permanently connected products. Inspections typically only occur during construction or renovation. NRTL approval is expected for line-voltage products. Many large retailers won’t carry products unless they have NRTL approval. However, there are plenty of on-line and physical stores that don’t have NRTL requirements for the products they sell. OSHA under the Department of Labor sets requirements for the workplace and OSHA does mandate NRTL approvals. OSHA actually manages the NRTL program as noted by one of the earlier commenters. The standard for a keyboard depends on how it is used. I had a colleague that worked on 60601 approval for a keyboard used in medical applications. For the office, it would be UL 60950-1 or UL 62368-1, with the former standard being withdrawn in late 2020 if I recall correctly. The application in the U.S. is different than in Europe. Products certified to UL 60950-1 can continue to carry the certification mark after the date of withdrawal of the standard. Another date may be set further in the future when UL 60950-1 products would then need to be recertified to UL 62368-1. Keyboards that are USB powered or use alkaline batteries technically fall under the OSHA requirements, but are generally considered low enough power that it is extremely unlikely that an inspector would require them to be NRTL approved. If a keyboard is included in the retail package with an NRTL Listed computer, the NRTL may require the keyboard to be a Listed Accessory. Many NRTLs will require all included electrical accessories to be Listed if they are included in the same SKU with an NRTL Listed product. Ted Eckert Microsoft Corporation The opinions expressed are my own and do not necessarily reflect those of my employer. From: James Pawson (U3C) mailto:ja...@unit3compliance.co.uk> > Sent: Tuesday, June 19, 2018 1:56 AM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] UL Listing of Computer Keyboard Hi all, Thanks very much for the illuminating replies, it’s a great help. To summarise (and to make sure I’ve understood): * NRTL approval legally required for selling in the USA? No. * NRTL / UL approval expected? Highly likely. * NRTL approval required for use in the workplace? Yes, not legally required but market expectation? Or is it a legal requirement? * Standard used: UL 62368-1 @Pete Perkins: are you saying when the LVD was recast that they tried to remove the lower voltage limit? Presumably this didn’t happen because companies didn’t want the extra workload involved with extra testing / assessment? Having looked at EN 62368-1, there’s not a great deal in there that applies to a low power device such as a USB powered keyboard so I think it’s fair to say that the type approval wouldn’t take a great deal of time / cost. Reading http://www.productapprovals.co.uk/ul-approval.html <https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.productapprovals.co.uk%2Ful-approval.html=02%7C01%7Cted.eckert%40microsoft.com%7C2e125d75d5f34301aba908d5d5c28d35%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636649953933516570=PsT2iw7EGYBVEVI9oyBGoMJRFyNzLXKp9%2BXwCswulrU%3D=0> there appear to be initial and regular factory inspections associated with a NRTL listing, with the figure of a few thousand dollars being quoted as a typical fee for maintaining an NRTL mark. Does this match people’s experience? If the factory already has NRTL approval for manufacturing another product, could one piggyback onto this approval or is it on a per product basis? Thanks again James - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org> > All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pse
Re: [PSES] UL Listing of Computer Keyboard
Brian, I always appreciate your comments based upon your experience and your enthusiastic cynicism toward life. Altho I tried to separate the variables it appears that I did not do it sufficiently. In my prior post I allowed as how the certification expenses are on a product or product family basis including associated certificate costs. The FUS, however, is based upon factory location and by similar equipment group (e.g. UL Efile #s); the inspection is based upon looking at something in each equipment group so not every product type is examined each FUS Qtly visit. Further the inspection time/cost is fixed so that the FUS cost to the mfgr is spread out over the units produced , whether a single product or several related products and includes the volume (not from the inspectors point of view but from the mfgrs bean counter point of view). My example pointed to this type of scenario. Perhaps this provides more clarification. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 IEEE Life Fellow p.perk...@ieee.org -Original Message- From: Brian O'Connell Sent: Tuesday, June 19, 2018 10:43 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard FUS audit and certification and license costs are not necessarily able to be distributed over a larger production number; will depend on the particular NRTL/SCC. For many product combinations, there is no cost efficiency for volume or for factory consolidation for the respective 'regulatory' remit. The agencies will always find a way to structure fees and processes to extract maximum dollars and minimize engineering time. That is, for any given agency, invoiced line items will always increase, while provided services will always decrease. Doubleplusgood. Less is more. Brian Senior News Reviewer of Oceania From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] Sent: Tuesday, June 19, 2018 8:56 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard James, As an American I’m not privy to the inner workings of making the sausage called EU Directives. However, there is a political process involved an all of this work and I’m sure that manufacturers and political regulators pushed back and forth to get to the final result for the update to the LVD. I agree with your assessment that companies don’t want the extra cost of type approval and have prevailed at this point for this set of circumstances. Somewhat related comment; since your keyboard is USB powered you need to understand that USB, like POE, is going to higher power delivery – 100W coming for USB3. There are additional issues that need to be addressed and IEC 62368-3 addresses power over communication cables no matter what the product type is; products using such comm cables will need to be assessed to ensure that they provide the proper protection coming and going when attached to these common outlet sockets. Again, NRTL certification is appropriate for evaluating this equipment. Finally, yes, these NRTL certifications are on a product by product basis; you can bunch similar models into one certification report tho. From experience, the FUS unit cost decreases as there is more product produced. Increasing the volume of either a product model or adding more similar models will drive down the unit cost as the inspection time is spread over more models and units. For instance for your 1K dollars/Euros or whatever, if the factory only produces a single unit per inspection quarter then that unit eats the entire cost; if the factory produces 10K units per inspection quarter then the unit cost is quite cheap. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 IEEE Life Fellow p.perk...@ieee.org - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: - This message is from the IEEE Product Safety Engin
Re: [PSES] UL Listing of Computer Keyboard
FUS audit and certification and license costs are not necessarily able to be distributed over a larger production number; will depend on the particular NRTL/SCC. For many product combinations, there is no cost efficiency for volume or for factory consolidation for the respective 'regulatory' remit. The agencies will always find a way to structure fees and processes to extract maximum dollars and minimize engineering time. That is, for any given agency, invoiced line items will always increase, while provided services will always decrease. Doubleplusgood. Less is more. Brian Senior News Reviewer of Oceania From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] Sent: Tuesday, June 19, 2018 8:56 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard James, As an American I’m not privy to the inner workings of making the sausage called EU Directives. However, there is a political process involved an all of this work and I’m sure that manufacturers and political regulators pushed back and forth to get to the final result for the update to the LVD. I agree with your assessment that companies don’t want the extra cost of type approval and have prevailed at this point for this set of circumstances. Somewhat related comment; since your keyboard is USB powered you need to understand that USB, like POE, is going to higher power delivery – 100W coming for USB3. There are additional issues that need to be addressed and IEC 62368-3 addresses power over communication cables no matter what the product type is; products using such comm cables will need to be assessed to ensure that they provide the proper protection coming and going when attached to these common outlet sockets. Again, NRTL certification is appropriate for evaluating this equipment. Finally, yes, these NRTL certifications are on a product by product basis; you can bunch similar models into one certification report tho. From experience, the FUS unit cost decreases as there is more product produced. Increasing the volume of either a product model or adding more similar models will drive down the unit cost as the inspection time is spread over more models and units. For instance for your 1K dollars/Euros or whatever, if the factory only produces a single unit per inspection quarter then that unit eats the entire cost; if the factory produces 10K units per inspection quarter then the unit cost is quite cheap. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 IEEE Life Fellow p.perk...@ieee.org - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] UL Listing of Computer Keyboard
James, As an American I’m not privy to the inner workings of making the sausage called EU Directives. However, there is a political process involved an all of this work and I’m sure that manufacturers and political regulators pushed back and forth to get to the final result for the update to the LVD. I agree with your assessment that companies don’t want the extra cost of type approval and have prevailed at this point for this set of circumstances. Somewhat related comment; since your keyboard is USB powered you need to understand that USB, like POE, is going to higher power delivery – 100W coming for USB3. There are additional issues that need to be addressed and IEC 62368-3 addresses power over communication cables no matter what the product type is; products using such comm cables will need to be assessed to ensure that they provide the proper protection coming and going when attached to these common outlet sockets. Again, NRTL certification is appropriate for evaluating this equipment. Finally, yes, these NRTL certifications are on a product by product basis; you can bunch similar models into one certification report tho. From experience, the FUS unit cost decreases as there is more product produced. Increasing the volume of either a product model or adding more similar models will drive down the unit cost as the inspection time is spread over more models and units. For instance for your 1K dollars/Euros or whatever, if the factory only produces a single unit per inspection quarter then that unit eats the entire cost; if the factory produces 10K units per inspection quarter then the unit cost is quite cheap. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 IEEE Life Fellow <mailto:p.perk...@ieee.org> p.perk...@ieee.org From: James Pawson (U3C) Sent: Tuesday, June 19, 2018 1:56 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard Hi all, Thanks very much for the illuminating replies, it’s a great help. To summarise (and to make sure I’ve understood): * NRTL approval legally required for selling in the USA? No. * NRTL / UL approval expected? Highly likely. * NRTL approval required for use in the workplace? Yes, not legally required but market expectation? Or is it a legal requirement? * Standard used: UL 62368-1 @Pete Perkins: are you saying when the LVD was recast that they tried to remove the lower voltage limit? Presumably this didn’t happen because companies didn’t want the extra workload involved with extra testing / assessment? Having looked at EN 62368-1, there’s not a great deal in there that applies to a low power device such as a USB powered keyboard so I think it’s fair to say that the type approval wouldn’t take a great deal of time / cost. Reading http://www.productapprovals.co.uk/ul-approval.html there appear to be initial and regular factory inspections associated with a NRTL listing, with the figure of a few thousand dollars being quoted as a typical fee for maintaining an NRTL mark. Does this match people’s experience? If the factory already has NRTL approval for manufacturing another product, could one piggyback onto this approval or is it on a per product basis? Thanks again James From: Pete Perkins <0061f3f32d0c-dmarc-requ...@ieee.org <mailto:0061f3f32d0c-dmarc-requ...@ieee.org> > Sent: 19 June 2018 00:27 To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] UL Listing of Computer Keyboard Dave, et al, I think that you are simplifying the discussion too much. Certainly a wall-wart with an ELV output is not an electric shock hazard but that is no guarantee that any NRTL wall-wart power supply will not start a fire in any device which it powers; that can only be determined by inspection and testing. James, is your keyboard wireless? The EU has long had an ELV exclusion for equipment under the LVD. But, because of the issue raised here, there was an effort to remove that in the last update to the LVD which, unfortunately, failed. So a partial fix is that if a device has a radio in it must meet the Radio Equipment Directive and that RED Directive encompasses all of the hazards such that the electrical safety standards used under the LVD now apply except that the ELV exclusion is eliminated; a step in the right direction, I believe. (So the LVD is not invoked of itself when meeting the RED directive but the appropriate safety standard is.) Now it is obvious why Rich Nute’s Bluetooth mouse bears appropriate safety marks. :>) br, Pete Peter E Perkins, PE Principal Product Safety &
Re: [PSES] UL Listing of Computer Keyboard
NRTL approval is not a legal requirement to sell a product in the United States. There is no national legal requirement for many types of consumer products. Many jurisdictions have adopted NFPA 70, the National Electrical Code, which requires products either to be Listed by an NRTL or to be approved by the local inspector. This creates a de facto NRTL requirement for most permanently connected products. Inspections typically only occur during construction or renovation. NRTL approval is expected for line-voltage products. Many large retailers won’t carry products unless they have NRTL approval. However, there are plenty of on-line and physical stores that don’t have NRTL requirements for the products they sell. OSHA under the Department of Labor sets requirements for the workplace and OSHA does mandate NRTL approvals. OSHA actually manages the NRTL program as noted by one of the earlier commenters. The standard for a keyboard depends on how it is used. I had a colleague that worked on 60601 approval for a keyboard used in medical applications. For the office, it would be UL 60950-1 or UL 62368-1, with the former standard being withdrawn in late 2020 if I recall correctly. The application in the U.S. is different than in Europe. Products certified to UL 60950-1 can continue to carry the certification mark after the date of withdrawal of the standard. Another date may be set further in the future when UL 60950-1 products would then need to be recertified to UL 62368-1. Keyboards that are USB powered or use alkaline batteries technically fall under the OSHA requirements, but are generally considered low enough power that it is extremely unlikely that an inspector would require them to be NRTL approved. If a keyboard is included in the retail package with an NRTL Listed computer, the NRTL may require the keyboard to be a Listed Accessory. Many NRTLs will require all included electrical accessories to be Listed if they are included in the same SKU with an NRTL Listed product. Ted Eckert Microsoft Corporation The opinions expressed are my own and do not necessarily reflect those of my employer. From: James Pawson (U3C) Sent: Tuesday, June 19, 2018 1:56 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard Hi all, Thanks very much for the illuminating replies, it’s a great help. To summarise (and to make sure I’ve understood): * NRTL approval legally required for selling in the USA? No. * NRTL / UL approval expected? Highly likely. * NRTL approval required for use in the workplace? Yes, not legally required but market expectation? Or is it a legal requirement? * Standard used: UL 62368-1 @Pete Perkins: are you saying when the LVD was recast that they tried to remove the lower voltage limit? Presumably this didn’t happen because companies didn’t want the extra workload involved with extra testing / assessment? Having looked at EN 62368-1, there’s not a great deal in there that applies to a low power device such as a USB powered keyboard so I think it’s fair to say that the type approval wouldn’t take a great deal of time / cost. Reading http://www.productapprovals.co.uk/ul-approval.html<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.productapprovals.co.uk%2Ful-approval.html=02%7C01%7Cted.eckert%40microsoft.com%7C2e125d75d5f34301aba908d5d5c28d35%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636649953933516570=PsT2iw7EGYBVEVI9oyBGoMJRFyNzLXKp9%2BXwCswulrU%3D=0> there appear to be initial and regular factory inspections associated with a NRTL listing, with the figure of a few thousand dollars being quoted as a typical fee for maintaining an NRTL mark. Does this match people’s experience? If the factory already has NRTL approval for manufacturing another product, could one piggyback onto this approval or is it on a per product basis? Thanks again James - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] UL Listing of Computer Keyboard
Hi all, Thanks very much for the illuminating replies, it’s a great help. To summarise (and to make sure I’ve understood): * NRTL approval legally required for selling in the USA? No. * NRTL / UL approval expected? Highly likely. * NRTL approval required for use in the workplace? Yes, not legally required but market expectation? Or is it a legal requirement? * Standard used: UL 62368-1 @Pete Perkins: are you saying when the LVD was recast that they tried to remove the lower voltage limit? Presumably this didn’t happen because companies didn’t want the extra workload involved with extra testing / assessment? Having looked at EN 62368-1, there’s not a great deal in there that applies to a low power device such as a USB powered keyboard so I think it’s fair to say that the type approval wouldn’t take a great deal of time / cost. Reading http://www.productapprovals.co.uk/ul-approval.html there appear to be initial and regular factory inspections associated with a NRTL listing, with the figure of a few thousand dollars being quoted as a typical fee for maintaining an NRTL mark. Does this match people’s experience? If the factory already has NRTL approval for manufacturing another product, could one piggyback onto this approval or is it on a per product basis? Thanks again James From: Pete Perkins <0061f3f32d0c-dmarc-requ...@ieee.org> Sent: 19 June 2018 00:27 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard Dave, et al, I think that you are simplifying the discussion too much. Certainly a wall-wart with an ELV output is not an electric shock hazard but that is no guarantee that any NRTL wall-wart power supply will not start a fire in any device which it powers; that can only be determined by inspection and testing. James, is your keyboard wireless? The EU has long had an ELV exclusion for equipment under the LVD. But, because of the issue raised here, there was an effort to remove that in the last update to the LVD which, unfortunately, failed. So a partial fix is that if a device has a radio in it must meet the Radio Equipment Directive and that RED Directive encompasses all of the hazards such that the electrical safety standards used under the LVD now apply except that the ELV exclusion is eliminated; a step in the right direction, I believe. (So the LVD is not invoked of itself when meeting the RED directive but the appropriate safety standard is.) Now it is obvious why Rich Nute’s Bluetooth mouse bears appropriate safety marks. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 IEEE Life Fellow <mailto:p.perk...@ieee.org> p.perk...@ieee.org From: Nyffenegger, Dave mailto:dave.nyffeneg...@bhemail.com> > Sent: Monday, June 18, 2018 1:15 PM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] UL Listing of Computer Keyboard This is generally true however there are plenty of examples of products for sale as well as those used in the workplace that are simple in nature and/or non-hazardous and do not carry an NRTL mark. For example, the stapler on your desk or even the phone on your desk. If it plugs into a power outlet in the wall it needs NRTL. A computer keyboard could have one but is it really needed? The main reason a lot of OEMs use wall warts is they NRTL certify the wall wart (or more likely source one from another OEM) but not the product that it supplies power to as it doesn’t need it. -Dave From: Monrad Monsen [mailto:monrad.mon...@oracle.com] Sent: Monday, June 18, 2018 12:02 PM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] UL Listing of Computer Keyboard Hi James, Please note that the OSHA Nationally Recognized Test Laboratory (NRTL) will verify your product to UL62368-1 standard (based on international IEC62368-1). The OSHA regulation mandates that employers provide a safe working environment for employees (and local building codes support those requirements) plus retail stores don’t want to be sued for selling unsafe products if someone is harmed or property damaged, so neither employers nor retail stores will buy or re-sell a product that does not have a NRTL approval. As Darren notes, NRTL labs are not just UL but also CSA, TUV Rheinland, TUV Sud, ETL (Intertek), Nemko, etc. A full listing is at the web page below: https://www.osha.gov/dts/otpca/nrtl/nrtllist.html Hope this helps. Monrad Sent from my iPhone On Jun 18, 2018, at 3:03 AM, CATHERINE PEARSON <0b0df63784fb-dmarc-requ...@ieee.org <mailto:0b0df63784fb-dmarc-requ...@ieee.org> > wrote: Hi James, Is UL listing mandator
Re: [PSES] UL Listing of Computer Keyboard
Dave, et al, I think that you are simplifying the discussion too much. Certainly a wall-wart with an ELV output is not an electric shock hazard but that is no guarantee that any NRTL wall-wart power supply will not start a fire in any device which it powers; that can only be determined by inspection and testing. James, is your keyboard wireless? The EU has long had an ELV exclusion for equipment under the LVD. But, because of the issue raised here, there was an effort to remove that in the last update to the LVD which, unfortunately, failed. So a partial fix is that if a device has a radio in it must meet the Radio Equipment Directive and that RED Directive encompasses all of the hazards such that the electrical safety standards used under the LVD now apply except that the ELV exclusion is eliminated; a step in the right direction, I believe. (So the LVD is not invoked of itself when meeting the RED directive but the appropriate safety standard is.) Now it is obvious why Rich Nute’s Bluetooth mouse bears appropriate safety marks. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 IEEE Life Fellow <mailto:p.perk...@ieee.org> p.perk...@ieee.org From: Nyffenegger, Dave Sent: Monday, June 18, 2018 1:15 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard This is generally true however there are plenty of examples of products for sale as well as those used in the workplace that are simple in nature and/or non-hazardous and do not carry an NRTL mark. For example, the stapler on your desk or even the phone on your desk. If it plugs into a power outlet in the wall it needs NRTL. A computer keyboard could have one but is it really needed? The main reason a lot of OEMs use wall warts is they NRTL certify the wall wart (or more likely source one from another OEM) but not the product that it supplies power to as it doesn’t need it. -Dave From: Monrad Monsen [mailto:monrad.mon...@oracle.com] Sent: Monday, June 18, 2018 12:02 PM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] UL Listing of Computer Keyboard Hi James, Please note that the OSHA Nationally Recognized Test Laboratory (NRTL) will verify your product to UL62368-1 standard (based on international IEC62368-1). The OSHA regulation mandates that employers provide a safe working environment for employees (and local building codes support those requirements) plus retail stores don’t want to be sued for selling unsafe products if someone is harmed or property damaged, so neither employers nor retail stores will buy or re-sell a product that does not have a NRTL approval. As Darren notes, NRTL labs are not just UL but also CSA, TUV Rheinland, TUV Sud, ETL (Intertek), Nemko, etc. A full listing is at the web page below: https://www.osha.gov/dts/otpca/nrtl/nrtllist.html Hope this helps. Monrad Sent from my iPhone On Jun 18, 2018, at 3:03 AM, CATHERINE PEARSON <0b0df63784fb-dmarc-requ...@ieee.org <mailto:0b0df63784fb-dmarc-requ...@ieee.org> > wrote: Hi James, Is UL listing mandatory for IT accessories like keyboards? No any NRTL certification will be sufficient, but that may not be the question or answer ! Depending where you are selling the equipment, they may expect a certain certification mark, Ive gotten many approvals for the USA market but its the customer who needs to understand the requirements. I had explained to my customer that they can have any suitable certification mark and it will meet the requirements, TUV, CSA, UL etc However once they were selling the device, there customer would ask "Wheres the UL mark" there customer was not technical and didn't understand or care to understand there were alternatives, just "Wheres the UL mark" Ive also found this with the building inspectors who should know better ! So for that job, nothing but UL would do. In answer to "some retailers use it as a minimum requirement for stocking your products" Yes thats correct and you dont have much chance in convincing them to do anything else. I've been discussing this with the alternative approval bodies for a while, that they need to improve the general public view of them so more people understand that UL are only one of a number of options. Ive worked with many approval bodies, some better than others, some not, but as a general rule, avoid the customer service agents and deal straight with the engineer at the testing lab and the person whos dealing with the approval. I have to mention my current experience with UL is very good, but then ive found myself a number of responsive people who reply to your Emails and are happy
Re: [PSES] UL Listing of Computer Keyboard
Yes. But, the NRTLs would like the project (dollars). As previously mentioned, the inspectors only know that it is “electric” therefore it must be certified. Even my Bluetooth mouse is certified. Rich From: Nyffenegger, Dave Sent: Monday, June 18, 2018 1:15 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard This is generally true however there are plenty of examples of products for sale as well as those used in the workplace that are simple in nature and/or non-hazardous and do not carry an NRTL mark. For example, the stapler on your desk or even the phone on your desk. If it plugs into a power outlet in the wall it needs NRTL. A computer keyboard could have one but is it really needed? The main reason a lot of OEMs use wall warts is they NRTL certify the wall wart (or more likely source one from another OEM) but not the product that it supplies power to as it doesn’t need it. -Dave - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] UL Listing of Computer Keyboard
This is generally true however there are plenty of examples of products for sale as well as those used in the workplace that are simple in nature and/or non-hazardous and do not carry an NRTL mark. For example, the stapler on your desk or even the phone on your desk. If it plugs into a power outlet in the wall it needs NRTL. A computer keyboard could have one but is it really needed? The main reason a lot of OEMs use wall warts is they NRTL certify the wall wart (or more likely source one from another OEM) but not the product that it supplies power to as it doesn’t need it. -Dave From: Monrad Monsen [mailto:monrad.mon...@oracle.com] Sent: Monday, June 18, 2018 12:02 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard Hi James, Please note that the OSHA Nationally Recognized Test Laboratory (NRTL) will verify your product to UL62368-1 standard (based on international IEC62368-1). The OSHA regulation mandates that employers provide a safe working environment for employees (and local building codes support those requirements) plus retail stores don’t want to be sued for selling unsafe products if someone is harmed or property damaged, so neither employers nor retail stores will buy or re-sell a product that does not have a NRTL approval. As Darren notes, NRTL labs are not just UL but also CSA, TUV Rheinland, TUV Sud, ETL (Intertek), Nemko, etc. A full listing is at the web page below: https://www.osha.gov/dts/otpca/nrtl/nrtllist.html Hope this helps. Monrad Sent from my iPhone On Jun 18, 2018, at 3:03 AM, CATHERINE PEARSON <0b0df63784fb-dmarc-requ...@ieee.org<mailto:0b0df63784fb-dmarc-requ...@ieee.org>> wrote: Hi James, Is UL listing mandatory for IT accessories like keyboards? No any NRTL certification will be sufficient, but that may not be the question or answer ! Depending where you are selling the equipment, they may expect a certain certification mark, Ive gotten many approvals for the USA market but its the customer who needs to understand the requirements. I had explained to my customer that they can have any suitable certification mark and it will meet the requirements, TUV, CSA, UL etc However once they were selling the device, there customer would ask "Wheres the UL mark" there customer was not technical and didn't understand or care to understand there were alternatives, just "Wheres the UL mark" Ive also found this with the building inspectors who should know better ! So for that job, nothing but UL would do. In answer to "some retailers use it as a minimum requirement for stocking your products" Yes thats correct and you dont have much chance in convincing them to do anything else. I've been discussing this with the alternative approval bodies for a while, that they need to improve the general public view of them so more people understand that UL are only one of a number of options. Ive worked with many approval bodies, some better than others, some not, but as a general rule, avoid the customer service agents and deal straight with the engineer at the testing lab and the person whos dealing with the approval. I have to mention my current experience with UL is very good, but then ive found myself a number of responsive people who reply to your Emails and are happy to discuss the project with you. 10 years ago, it was a lot different ! Regards Darren. On Monday, 18 June 2018, 9:40, James Pawson (U3C) mailto:ja...@unit3compliance.co.uk>> wrote: Hi folks, Working with a client at the moment on a computer keyboard (hence the earlier question). I’m trying to get a handle on the applicability of UL listing and could do with some help. Is UL listing mandatory for IT accessories like keyboards? My searching so far suggests that the answer is “no”. However, I’ve read that some retailers use it as a minimum requirement for stocking your products – does anyone have any experience or knowledge of this? Assuming that UL listing was required (for whatever reason, OHSA?) presumably an analysis against IEC 62368-1 would be sufficient or are there other tests/requirements? If anyone has a link to any docs with more information I’d like to do some more reading up. Thanks in advance James - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.ieee-2Dpses.org_emc-2Dpstc.html=DwMFaQ=RoP1YumCXCgaWHvlZYR8PZh8Bv7qIrMUB65eapI_JnE=bdhQMzFxnmYEOUrCJpiaOszYW-e590kX_eWuZIISyNU=Z5flFx27FjfcBamtvZYcgOBNAdsqWj8Zn2RSr2e6sCk=K86KMprMkbphA5kyRQLT1Vo_babz413uEwQ4Fi6lMsw=> Attachments are not permitted
Re: [PSES] UL Listing of Computer Keyboard
Hi James, Please note that the OSHA Nationally Recognized Test Laboratory (NRTL) will verify your product to UL62368-1 standard (based on international IEC62368-1). The OSHA regulation mandates that employers provide a safe working environment for employees (and local building codes support those requirements) plus retail stores don’t want to be sued for selling unsafe products if someone is harmed or property damaged, so neither employers nor retail stores will buy or re-sell a product that does not have a NRTL approval. As Darren notes, NRTL labs are not just UL but also CSA, TUV Rheinland, TUV Sud, ETL (Intertek), Nemko, etc. A full listing is at the web page below: https://www.osha.gov/dts/otpca/nrtl/nrtllist.html Hope this helps. Monrad Sent from my iPhone > On Jun 18, 2018, at 3:03 AM, CATHERINE PEARSON > <0b0df63784fb-dmarc-requ...@ieee.org> wrote: > > Hi James, > > Is UL listing mandatory for IT accessories like keyboards? > No any NRTL certification will be sufficient, but that may not be the > question or answer ! > > Depending where you are selling the equipment, they may expect a certain > certification mark, > Ive gotten many approvals for the USA market but its the customer who needs > to understand the requirements. > > I had explained to my customer that they can have any suitable certification > mark and it will meet the requirements, TUV, CSA, UL etc > However once they were selling the device, there customer would ask "Wheres > the UL mark" > there customer was not technical and didn't understand or care to understand > there were alternatives, just "Wheres the UL mark" > Ive also found this with the building inspectors who should know better ! > > So for that job, nothing but UL would do. > In answer to "some retailers use it as a minimum requirement for stocking > your products" > Yes thats correct and you dont have much chance in convincing them to do > anything else. > I've been discussing this with the alternative approval bodies for a while, > that they need to improve the general public view of them so more people > understand that UL are only one of a number of options. > > Ive worked with many approval bodies, some better than others, some not, > but as a general rule, avoid the customer service agents and deal straight > with the engineer at the testing lab and the person whos dealing with the > approval. > > I have to mention my current experience with UL is very good, but then ive > found myself a number of responsive people who reply to your Emails and are > happy to discuss the project with you. > > 10 years ago, it was a lot different ! > > Regards Darren. > > > > > > > > > > > > On Monday, 18 June 2018, 9:40, James Pawson (U3C) > wrote: > > > Hi folks, > > Working with a client at the moment on a computer keyboard (hence the earlier > question). I’m trying to get a handle on the applicability of UL listing and > could do with some help. > > Is UL listing mandatory for IT accessories like keyboards? My searching so > far suggests that the answer is “no”. However, I’ve read that some retailers > use it as a minimum requirement for stocking your products – does anyone have > any experience or knowledge of this? > > Assuming that UL listing was required (for whatever reason, OHSA?) presumably > an analysis against IEC 62368-1 would be sufficient or are there other > tests/requirements? > > If anyone has a link to any docs with more information I’d like to do some > more reading up. > > Thanks in advance > James > > > > > > - > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > Attachments are not permitted but the IEEE PSES Online Communities site at > http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used > formats), large files, etc. > Website: http://www.ieee-pses.org/ > Instructions: http://www.ieee-pses.org/list.html (including how to > unsubscribe) > List rules: http://www.ieee-pses.org/listrules.html > For help, send mail to the list administrators: > Scott Douglas > Mike Cantwell > For policy questions, send mail to: > Jim Bacher > David Heald > > > - > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to > > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > Attachments are not permitted but the IEEE PSES Online Communities site at > http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used > formats), large files, etc. >
Re: [PSES] UL Listing of Computer Keyboard
Hi James, Is UL listing mandatory for IT accessories like keyboards? No any NRTL certification will be sufficient, but that may not be the question or answer ! Depending where you are selling the equipment, they may expect a certain certification mark, Ive gotten many approvals for the USA market but its the customer who needs to understand the requirements. I had explained to my customer that they can have any suitable certification mark and it will meet the requirements, TUV, CSA, UL etc However once they were selling the device, there customer would ask "Wheres the UL mark" there customer was not technical and didn't understand or care to understand there were alternatives, just "Wheres the UL mark" Ive also found this with the building inspectors who should know better ! So for that job, nothing but UL would do. In answer to "some retailers use it as a minimum requirement for stocking your products" Yes thats correct and you dont have much chance in convincing them to do anything else. I've been discussing this with the alternative approval bodies for a while, that they need to improve the general public view of them so more people understand that UL are only one of a number of options. Ive worked with many approval bodies, some better than others, some not, but as a general rule, avoid the customer service agents and deal straight with the engineer at the testing lab and the person whos dealing with the approval. I have to mention my current experience with UL is very good, but then ive found myself a number of responsive people who reply to your Emails and are happy to discuss the project with you. 10 years ago, it was a lot different ! Regards Darren. On Monday, 18 June 2018, 9:40, James Pawson (U3C) wrote: Hi folks, Working with a client at the moment on a computer keyboard (hence the earlier question). I’m trying to get a handle on the applicability of UL listing and could do with some help. Is UL listing mandatory for IT accessories like keyboards? My searching so far suggests that the answer is “no”. However, I’ve read that some retailers use it as a minimum requirement for stocking your products – does anyone have any experience or knowledge of this? Assuming that UL listing was required (for whatever reason, OHSA?) presumably an analysis against IEC 62368-1 would be sufficient or are there other tests/requirements? If anyone has a link to any docs with more information I’d like to do some more reading up. Thanks in advanceJames - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at:http://www.ieee-pses.org/emc-pstc.htmlAttachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc.Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.htmlFor help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher David Heald - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
[PSES] UL Listing of Computer Keyboard
Hi folks, Working with a client at the moment on a computer keyboard (hence the earlier question). I'm trying to get a handle on the applicability of UL listing and could do with some help. Is UL listing mandatory for IT accessories like keyboards? My searching so far suggests that the answer is "no". However, I've read that some retailers use it as a minimum requirement for stocking your products - does anyone have any experience or knowledge of this? Assuming that UL listing was required (for whatever reason, OHSA?) presumably an analysis against IEC 62368-1 would be sufficient or are there other tests/requirements? If anyone has a link to any docs with more information I'd like to do some more reading up. Thanks in advance James - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
