The following is strictly opinion ...

I may be sticking my neck way out here, but it is my understanding
that any required manufacturing hi-pot test, with regard to UL-1950,
is contractual between the mfr of said device and the testing NRTL.
To my knowledge, there is no *requirement* within the standard
which warrants manufacturing hi-pot test. The standard merely gives
a guide if it is so chosen to be done.

After testing, the NRTL may submit the mfr to lots of requirements
not within the standard.  And if one were to read the standard to the
letter, there's tons of contractual arrengements not stated in the
standard.

This is why I have a difficult time explaining to some people the
real meaning of the NRTL label when it is applied to the product.
It's subtle I know, but the real meaning of the label is not one of
"approval', it's really a sign of a "continued contractual
arrangement"
between you and the NRTL.

Some people think of the NRTL label as a sort of medal as one would
win in some sporting event.  Years after, you may still have the medal
but no longer compete.  Not so with an NRTL label.  If there were no
contractual agreement behind it, then upon successful completion of
the
testing you could apply the label and be done with the NRTL forever.
And as such, failure to maintain requirements after testing can result
with the label being pulled.  In the case of someplace such as Europe,
where self-declarartion is used, things can get more severe by having
a product pulled.

IMHO, if I were to address the initial question regarding
manufactoring
testing of a product bound for Europe - unless there were some severe
national deviation differences from a similar type of US domestic
approval
of the product, I'd continue along with hi-pot testing just as if the
product
were bound for a domestic (US) market.

Sorry for getting wrapped around the axle about this topic, but that's
my
3.1415 cents worth ...

- Doug



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