Do LED strip lights require UL listing?

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If you've worked with electronics and lighting, you will undoubtedly have encountered the familiar UL marking. As a low voltage product, however, you may be wondering if 12V and 24V LED strips are exempt from UL listing requirements. Read on to find out!

What is UL listing?

UL, formerly known as Underwriters Laboratory, is an agency that both develops product safety standards and performs product testing to see if they meet safety standards. Although UL develops many of these standards, other Nationally Recognized Testing Laboratories (NRTL) can also perform testing against the same UL standards. Because these alternative NRTLs offer lower pricing and faster turnaround times, many manufacturers often go down this route. You may come across other test agencies and certifications such as ETL and TUV.

Once a product is submitted for testing by a manufacturer, the product is tested against the UL standard for which the product is categorized under. 12V and 24V LED strips, for example, fall under the standard: UL2108, Low Voltage Lighting Systems. If it passes the test, the product is considered "listed" and will have the corresponding marking to distinguish this. For an LED strip, typically the UL or ETL logo, along with the corresponding file number is printed directly onto the surface of the LED strip substrate.

Who says LED strips require UL listing?

In the United States, before a construction project involving new buildings or renovations can begin, a variety of permit and inspection processes must take place. The specifics and Authorities Having Jurisdiction (AHJ) can depend on the particular region and locale, most will reference the National Electric Code (NEC), which lays out minimum requirements for protecting the safety of persons and property from injury and damage arising from the use of electricity.

Under the NEC, article 411 describes requirements for lighting systems operating under 30 volts or under connected to a Class 2 (less than 100W) power source.

Specifically, article 411 says:

Lighting systems operating at 30 volts or less shall comply with 411.3(A) or 411.3(B).

(A) Listed System. Lighting systems operating at 30 volts or less shall be listed as a complete system. The luminaires, power supply, and luminaire fittings (including the exposed bare conductors) of an exposed bare conductor lighting system shall be listed for the use as part of the same identified lighting system.

(B) Assembly of Listed Parts. A lighting system assembled from the following listed parts shall be permitted:
(1) Low-voltage luminaires
(2) Low-voltage luminaire power supply
(3) Class 2 power supply
(4) Low-voltage luminaire fittings
(5) Cord (secondary circuit) for which the luminaires and power supply are listed for use
(6) Cable, conductors in conduit, or other fixed wiring method for the secondary circuit
The luminaires, power supply, and luminaire fittings (including the exposed bare conductors) of an exposed bare conductor lighting system shall be listed for use as part of the same identified lighting system.

In other words, LED strip lights must be listed (UL/ETL or otherwise) as a part of a listed lighting system (e.g. LED strip lighting kit), or listed separately as one of the components of an assembled system.

Are LED strips exempt from UL requirements under NEC because they fall under Class 2?

Class 2 is a special designation for circuits which by definition are limited to a certain voltage (60V DC) and power (100W). Therefore, the electrical shock and fire risk are significantly lower for Class 2 circuits compared to those that plug directly into regular 120V/240V AC mains power supply. The safety precautions that need to be taken are correspondingly less stringent, and are reflected in NEC article 725, which lay out the types of wires and connection methods that are allowed.

What is noticeably absent is any designation exempting components in a Class 2 circuit from requiring listing. Oftentimes UL508a is erroneously cited as doing so, but this standard only applies to industrial control panels and not lighting circuits.

So, following the NEC requirements leads us to the conclusion that LED strips are not exempt from UL listing requirements, and that UL2108 (IFDR) is the standard that should be used in evaluating LED strip products.

The limitations of NEC requirements and situations where UL listing would NOT be needed for LED strips

What is very important to note is that the NEC regulations and requirements are not mandated by law, and it is therefore not illegal to install non-listed LED strips. Instead, as mentioned above, construction and renovation permits are approved and installations are inspected by the particular authority having jurisdiction (AHJ). In essence, interpretation and enforcement of the NEC rests on the AHJ.

The NEC itself lays this out thus:

The authority having jurisdiction for enforcement of the Code has the responsibility for making interpretations of the rules, for deciding on the approval of equipment and materials, and for granting the special permission contemplated in a number of the rules. By special permission, the authority having jurisdiction may waive specific requirements in this Code or permit alternative methods where it is assured that equivalent objectives can be achieved by establishing and maintaining effective safety.

In other words, if an AHJ believes that LED strips are inherently low-risk and pose virtually no shock or fire hazard, they are fully within their rights to approve non-listed LED strips to be used in an installation, and the NEC article 411 requirements are essentially rendered meaningless.

Oftentimes it is a business decision that also involves development and insurance companies and their willingness to take on the liability of potential property damage and personal injury. While installing a non-listed 120V light bulb may pose a significant shock and fire risk that companies are unwilling to take responsibility for, LED strips installed on an isolated Class 2 circuit may be considered low enough of a risk that a non-listed LED strip product would be approved. In the unlikely event that an LED strip does cause a fire, perhaps they would be able to maintain a strong position in court arguing that the LED strips should have been inherently safe in a Class 2 circuit.

What if no AHJ or inspector is involved? This is often the case for end-consumers who purchase non-listed LED strips directly. The seller is not breaking any laws, and neither is the buyer. This is oftentimes the case with lesser-known brands and online sellers, and there is nothing inherently wrong or illegal with this arrangement. In fact, buying and selling 120V AC light bulbs without UL listing is not illegal either, however, the risks here are significantly higher and therefore you will see very few sellers who do this, and buyers of these unlisted products take on significant injury and financial risk, likely without any legal recourse.

If I'm not required to use UL listed LED strips, is it still better to choose UL listed ones?

For manufacturers, receiving UL listing (or equivalent) can be a costly process. Therefore you will often find that UL listed LED strips have a higher price tag. But are there any benefits to paying the UL listing premium if the LED strip is not going into an installation that requires it?

While there are criticisms and concerns about UL's program, particularly surrounding their costs and pricing policies, the overall benefit of UL is that they help to alleviate the burden of legal and financial risk. If property damage or personal injury arises from the non-listed LED strip, for example, legal risks for both sides remain. For the seller, they would need to show that their product did not have any defects or design issues that contributed to the damage. For the buyer, their insurance companies may refuse to provide payment for damage claims due to their use of an unlisted product. In short, lawyers could potentially make the case that both the buyer and seller were negligent.

If property damage or personal injury arises from a UL listed LED strip, on the other hand, both the buyer and seller can make a strong case that they trusted that the UL marking signified a certain level of confidence in the safety of the product, and therefore avoiding the risk of any negligence claims.

Keep in mind that UL standards do not involve product performance, longevity or quality. So while a UL listed product may have gone through more stringent testing, this is solely based on an assessment of whether the product poses a shock or fire risk. It would therefore be wise to evaluate all aspects of an LED strip product, and not just the UL listing aspect.

Bottom line

Whether you are a manufacturer, distributor, contractor, DIYer/consumer, understanding the rules and regulations around UL listing for LED strips can be challenging but critical. For some projects, UL listing may be a prerequisite for approval, in which case you would have no choice but to seek only LED strip products who have received UL listing.

For other situations, however, it is less black and white, and more about your own assessment of the risks involved. It is certainly true that many of the risks of electric shock and fire are lower for LED strips, that does at all mean that they are eliminated or nonexistent. Be sure to consider all aspects of the situation, and when in doubt, consult a professional!

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