UL Certification for US Sales: Is It Required?

When UL certification is a legal duty, and when a buyer or platform asks for it

Brands that sell electrical products often ask us:

"We were told UL certification is mandatory for anything sold in the US. Is that true?"

"Our power supply is UL Recognized. Does that make the whole product certified?"

"Does it have to be UL, or can another lab do it?"

The short answer: federal law does not require UL certification for most consumer products. Certain workplace electrical equipment needs approval from a Nationally Recognized Testing Laboratory (NRTL). New York City requires UL standards for e-bikes, e-scooters and their batteries. Amazon names UL standards for specific categories.

The question to ask is not "Is it UL?" It is "Who requires it, and to which standard?"

1. Federal law: OSHA regulates employers, not manufacturers

UL certification is usually discussed as if it were a federal product rule. In practice, the main federal hook is workplace safety.

OSHA states it directly in its NRTL Program FAQ: "OSHA's authority is limited to employers; therefore, OSHA does not require manufacturers or suppliers, as applicable, to have the products they manufacture or supply certified by an NRTL."

An NRTL is a private lab that OSHA recognizes. Under 29 CFR 1910.7, it tests for safety and lists, labels or accepts equipment or materials.

For a typical consumer product sold at retail, there is no general federal duty to carry a UL mark.

2. Much workplace electrical equipment needs NRTL approval

The rule that does apply sits in OSHA's electrical standard. Under 29 CFR 1910.303(a), conductors and equipment "shall be acceptable only if approved, as defined in § 1910.399." The OSHA FAQ says that under 1910.303 OSHA requires NRTL approval for many kinds of electrical equipment used in the workplace.

Three limits apply:

OSHA's standards cover NRTL testing and certification for 39 product types (OSHA FAQ).
OSHA's list of product types notes that approval "may be required only under specific circumstances or conditions of use."
Local governments generally decide how far they accept NRTL certifications in their own codes (OSHA FAQ).

The duty lands on the employer that uses the equipment.

If your product will be used in a US office, factory or warehouse, check NRTL certification before you quote the buyer.

3. Where UL or NRTL certification is required: the comparison

Case	Who requires it	What is required
Consumer products in general	OSHA (federal)	No NRTL duty on manufacturers
Workplace electrical equipment	OSHA, 29 CFR 1910.303(a)	NRTL approval for many kinds of equipment
E-bikes, e-scooters and their batteries in NYC	New York City, from September 16, 2023	UL 2849, UL 2272, UL 2271
Power banks on Amazon	Amazon	UL 2056 or a named IEC/UL/CSA combination, plus UN 38.3
Electric space heaters on Amazon	Amazon	UL 1278
Hoverboards on Amazon	Amazon	UL 2272 and UN 38.3
Children's products covered by a children's product safety rule	CPSC	Testing by a CPSC-accepted lab and a Children's Product Certificate
Radio frequency (RF) devices	FCC	FCC equipment authorization

The last two rows are not UL rules. They are separate federal requirements that brands often mix up with UL.

4. New York City: UL standards for e-mobility devices and batteries

New York City is the clearest local example. According to the NYC Department of Consumer and Worker Protection, from September 16, 2023, battery-powered mobility devices and their lithium-ion batteries sold, leased or rented in the city must be certified by an accredited testing laboratory to UL standards.

The standards are:

UL 2849 for electric bicycles
UL 2272 for other battery-powered mobility devices, such as e-scooters
UL 2271 for storage batteries

The same product can face a UL requirement in one city and none in another.

5. Amazon: named standards and recent test reports

Amazon's requirements are category rules, not a general UL rule. Amazon names the exact standards.

For power banks, Amazon's portable power supplies policy lists three options, each with UN 38.3:

UL 2056
IEC/UL/CSA 62368-1 with IEC/UL/CSA 62133-2
IEC/UL/CSA 62368-1 with UL 2054

The test report must come from an ISO 17025-accredited lab and be issued within the previous 12 months. Sellers must work with a third-party testing, inspection and certification (TIC) provider that Amazon authorizes to verify the listings.

Other categories follow the same pattern. Electric space heaters must be tested to UL 1278. Hoverboards need UL 2272 and UN 38.3. Shipping rules for batteries are separate; our lithium battery shipping guide covers UN 38.3 and air limits.

On Amazon, the requirement is a named standard and a recent test report from an accredited lab.

6. UL Listed, UL Recognized and UL Classified are different marks

UL listing requirements depend on which mark you mean:

UL Listed: a complete, standalone product.
UL Recognized: a component built into a larger product. UL Solutions says it "is not a certification for a complete, standalone product."
UL Classified: a product evaluated for a specific hazard or for performance under specific conditions (UL Solutions).

UL also uses an enhanced "Certified" mark. UL says it carries the same meaning as its Listed or Classified marks. You can look up a UL mark's file number in the UL Product iQ database.

A UL Recognized power supply inside your product does not make the finished product certified.

7. UL is one NRTL among several

UL is not the only lab. OSHA "considers NRTLs recognized for the same product safety test standard to be capable of testing to, and certifying under, that standard" (OSHA FAQ).

On UL certification cost and time, there is no public price list. OSHA advises manufacturers to "contact one or more NRTLs directly to obtain a time and price quotation." Ask more than one NRTL that holds your standard in its scope.

Choose the lab by standard and scope, not by brand name.

Four checks before you sell

1. Is the product for consumers, or for use in a workplace?

2. Will it be sold, leased or rented in New York City as an e-mobility device or battery?

3. Is it in an Amazon category with named standards?

4. Is the finished product Listed, or only a component Recognized?

Product accidents are a separate question. Our product liability insurance guide covers what US retailers expect. Customs entry is a separate step, covered in our US customs clearance guide.

Wrap-up

UL certification is not a blanket rule for selling in the US. OSHA, New York City and Amazon each require it in defined cases, to named standards.

LinkONE offers US import regulation review, including CPSC and Prop 65, and customs support from its Fullerton, California warehouse. Testing and certification are done by NRTLs.

Find out who requires the certification and to which standard before you book a lab.

Frequently Asked Questions

Is UL certification required by law in the US?

Not for most consumer products. OSHA does not require manufacturers or suppliers to have products certified by an NRTL (OSHA FAQ). Workplace electrical equipment must be approved under 29 CFR 1910.303(a).

What is the difference between UL Listed and UL Recognized?

UL Listed marks a complete, standalone product. UL Recognized marks a component that goes into a larger product, and UL Solutions says it is not a certification for a complete product.

Is UL the only lab that can certify my product?

No. OSHA treats NRTLs recognized for the same test standard as capable of testing and certifying to it (OSHA FAQ).

How much does UL certification cost?

There is no public price list. OSHA tells manufacturers to contact one or more NRTLs directly for a time and price quotation (OSHA FAQ).

Does Amazon require UL certification?

Only for categories where Amazon names a standard. For power banks, Amazon lists UL 2056 or two IEC/UL/CSA combinations, each with UN 38.3, and a test report from an ISO 17025-accredited lab issued within the previous 12 months (Amazon).

Sources

Rules in this post are as of November 2026.

-LinkONE-