# UL label Required or not



## ADAguy (Jun 15, 2021)

Do solar photovoltaic (not connected to power sources) light fixtures as in path lighting  have to have UL labels? if attached to a building?


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## cda (Jun 15, 2021)

Interesting

Seems like they would have a UL, no matter what.

Low voltage ?? Only works when the sun goes down??

No real hazard??


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## Beniah Naylor (Jun 15, 2021)

That style of lighting is not covered by the NEC per the scope of Article 410 (Luminaires, Lampholders, and Lamps). It isn't specifically omitted, but they don't fall under any of the categories listed in 410.1. All of the types listed in that section appear to be hard-wired if you read the code sections.

My guess is that they are not required to be listed.


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## cda (Jun 15, 2021)

Looks like a no UL listing, imagine that:::

But looks like 2020, and not sure when manufactures would have to meet it











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## fatboy (Jun 15, 2021)

Not tied to the power supply, no requirement for a listing. JMHO


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## jar546 (Jun 15, 2021)

Beniah Naylor said:


> That style of lighting is not covered by the NEC per the scope of Article 410 (Luminaires, Lampholders, and Lamps). It isn't specifically omitted, but they don't fall under any of the categories listed in 410.1. All of the types listed in that section appear to be hard-wired if you read the code sections.
> 
> My guess is that they are not required to be listed.


Correct, only certain parts of the NEC *require* equipment to be listed and or labeled.  UL is not the only game in town anyway.


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## Mark K (Jun 15, 2021)

If that lighting is not covered by the NEC then on what basis does the building department have jurisdiction?


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## jar546 (Jun 16, 2021)

Mark K said:


> If that lighting is not covered by the NEC then on what basis does the building department have jurisdiction?


I am so glad that you asked.  Let's take a look at the NEC, shall we?

First, lighting is covered by the NEC.  Next lets look at the NEC

*Approved.* Acceptable to the authority having jurisdiction.

*Authority Having Jurisdiction (AHJ).* An organization, office,
or individual responsible for enforcing the requirements of a
code or standard, or for approving equipment, materials, an
installation, or a procedure.

110.2 Approval. The conductors and *equipment required or
permitted* by this Code shall be acceptable only if *approved.*
Informational Note: See 90.7, Examination of Equipment for
Safety, and 110.3, Examination, Identification, Installation, and
Use of Equipment. See definitions of Approved, Identified, Labeled,
and Listed.

110.3 Examination, Identification, Installation, Use, and Listing
(Product Certification) of Equipment.
(A) Examination. In judging equipment, considerations such
as the following shall be evaluated:
(1) Suitability for installation and use in conformity with the
provisions of this Code
Informational Note No. 1: Equipment may be new, reconditioned,
refurbished, or remanufactured.
Informational Note No. 2: Suitability of equipment use may be
identified by a description marked on or provided with a product
to identify the suitability of the product for a specific
purpose, environment, or application. Special conditions of use
or other limitations and other pertinent information may be
marked on the equipment, included in the product instructions,
or included in the appropriate listing and labeling information.
Suitability of equipment may be evidenced by listing or labeling.

Now for the breakdown.  Although the NEC does not explicitly required equipment to be listed and labeled, Chapter 1 places the burden of acceptance and approval squarely on the shoulders of the AHJ.  There are informational notes all over the NEC that discuss suitability of equipment, listing and labeling.  In addition, electrical training courses and seminars reiterate the importance of safety when approving electrical products, hence the list of approved agencies from the NRTL as UL is not the only game in town.

You will be hard pressed to find any AHJ that does not require listing and labeling of lighting equipment since approval of unlisted equipment opens up the AHJ and municipality that they represent to not just liability but the increased chance of a tragic event which the AHJ would have to live with.  Therefore, approval of electrical equipment legally sits squarely on the shoulders and within the authority of the AHJ.


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## JCraver (Jun 16, 2021)

There's no permit required for fixtures that are not tied to the grid.  Unless/until you run up against our zoning code "overspill" regulations, I have no authority to tell you what kind of solar lights you stick in your yard.  I don't want any, either.

This is something the insurance companies ought to take care of, and leave us out of it.


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## jar546 (Jun 16, 2021)

JCraver said:


> There's no permit required for fixtures that are not tied to the grid.  Unless/until you run up against our zoning code "overspill" regulations, I have no authority to tell you what kind of solar lights you stick in your yard.  I don't want any, either.
> 
> This is something the insurance companies ought to take care of, and leave us out of it.


I agree with that.


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## Mark K (Jun 16, 2021)

My question was not focused on whether the equipment needs to be listed but rather what is the limit of the applicability of the regulations and hence the jurisdiction of the building department..

I read the "acceptable to the authority having jurisdiction" to mean that the AHJ has found the item to comply with the objective criteria in the adopted regulations.  If the AHJ were to impose an additional requirement or introduce criteria that is not clearly addressed in the regulations then we have over reach. 

If you have an off the grid system that is not an integral part of the building I agree there is no jurisdiction.  

If you have an off the grid electrical system that is an integral part of the building my sense is that the electrical code would apply.   You have simply replaced the grid with the solar system that generates the power.

If the building code does not address a subject then there is no applicable criteria and thus there is no jurisdiction.  For example while the code has reporting requirements related to foundations there is no objective criteria how capacity of deep foundation systems should be calculated.  Thus the building department has nothing to say about the design of the deep foundation systems.  The code definitely recognizes deep foundation systems as acceptable but provides no technical criteria.  

On the other hand if the code addresses an issues and provides detailed criteria,  the use of an alternate method, not in the code, for deterring compliance is not acceptable.


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## jar546 (Jun 16, 2021)

Mark K said:


> ..........................................
> 
> If you have an off the grid system that is not an integral part of the building I agree there is no jurisdiction.
> 
> ...



I agree with both comments.


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