Hello Carl,

On Mon, 10 Apr 2006, Richards, Carl wrote:

> Dear Group,
>
> I am attempting to understand the limitations of shipping UL approved
> hardware under the following circumstances:
>
> 1. A modification made to an approved product without notification to UL
> of the change; and with the intent of not applying the UL mark when
> shipping the product

UL should have no interest in products shipped without their marks
present. With respect to the use of the word "approved". UL does not
"approve" anything - they "list" it.


> 2. A manufacturer certified to perform their own UL compliance subject
> to verification by UL, can the manufacturer build systems while waiting
> for final approvals; and would it be possible for the manufacturer to
> build and ship such a product without applying the UL mark?

Again, you can ship product that does not bear UL marks - but don't expect
to subsequently add the mark to those products without a field-inspection
later on. UL Marks are, in general, required to be applied at the point of
manufacture.

A real-world (not hypothetical) experience: I'm aware of products shipped
>from Asia with UL markings present, prior to the receipt of their
"Authorization to ship" letter. The manufacturer's position was that they
were in warehouses, awaiting receipt of the "Authorization".  The
warehouses, in fact, were containers on ships, headed for the U.S.
Obviously, this was a business decision (and a gamble that the
"Authorization" would be issued without requiring any modifications of the
product steaming in this direction). And, yes, the gamble paid off :-)

Best regards, Art Michael


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> I hasten to add, this is a hypothetical and educational question!
>
> Best Regards
>
> Carl
>
>
> Carl Richards,
> Regulatory Compliance Manager,
> Aspect Software
> 2, The Square
> Stockley Park, Uxbridge, UB11 1AD,
> United Kingdom
>
>
> +44 (0)208 589 1461 Office
> +44 (0)870 460 1950 Fax
> +44 (0)7875 27 1461  Mobile
> www.aspect.com
>
> -
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