When does a US retailer ask for UL or ETL listing even though the law does not?

Main answer · Wecent Editorial Team

Short answer: The buyer is not necessarily wrong, even if the law does not require a UL mark. OSHA’s NRTL programme covers workplace equipment, not consumer sales. But retailers, marketplaces and insurers can set their own requirements, and a listing from UL or another recognised lab such as Intertek (ETL) is the usual way to meet them.

What the law does and does not say

OSHA’s NRTL programme recognises laboratories that test and certify equipment for use in workplaces. It does not require manufacturers or suppliers of consumer products to obtain NRTL certification. For consumer products, CPSC rules focus on applicable safety rules and, where they apply, a certificate of conformity. A UL or ETL mark is not itself the legal certificate.

Why retailers ask for it anyway

• Risk. A listing from a recognised lab gives a retailer a third party that has tested the product to a published safety standard.
• Insurance and policy. Retailers and their insurers often write a listing requirement into their vendor rules.
• Marketplaces. Online marketplaces may set their own documentation requirements for chargers and ask for evidence from recognised labs.

Because these are commercial rules, they differ by buyer and change over time. Ask for the current requirement in writing.

UL and ETL

UL and Intertek’s ETL mark are both issued by laboratories that OSHA recognises as NRTLs. Intertek describes the ETL Listed Mark as showing that a product has been independently tested to meet published industry standards. A buyer who asks for UL may accept ETL, but you need that confirmed before you invest.

How to handle the request

1. Ask the buyer which standard and which marks are acceptable, and whether a listing for a similar model is enough.
2. Ask the factory which labs and reports it already holds. A lab’s factory-inspection requirements also apply.
3. Build the listing into the project plan and the unit price, including sample units and time.
4. Do not put a UL or ETL mark on a product that does not hold a listing in your name or under your brand arrangement.

Timing

Listing takes testing time and a factory inspection. Treat it as a gate before launch, not as paperwork you can finish after the first shipment.

Sources checked on 24 Oct 2026: OSHA: NRTL Program FAQ; CPSC: General Certificate of Conformity FAQ; Intertek: ETL Listed Mark.

Where this answer says to confirm with Wecent, the detail is not published on the product page and has to come from the datasheet or the factory. General facts come from the regulators, standards bodies or device makers named in the text.