Again many thanks to everyone who has replied, I’ve found the responses very useful.
All the best James From: Ted Eckert <000007cf6ebeab9d-dmarc-requ...@ieee.org> Sent: 19 June 2018 16:07 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard NRTL approval is not a legal requirement to sell a product in the United States. There is no national legal requirement for many types of consumer products. Many jurisdictions have adopted NFPA 70, the National Electrical Code, which requires products either to be Listed by an NRTL or to be approved by the local inspector. This creates a de facto NRTL requirement for most permanently connected products. Inspections typically only occur during construction or renovation. NRTL approval is expected for line-voltage products. Many large retailers won’t carry products unless they have NRTL approval. However, there are plenty of on-line and physical stores that don’t have NRTL requirements for the products they sell. OSHA under the Department of Labor sets requirements for the workplace and OSHA does mandate NRTL approvals. OSHA actually manages the NRTL program as noted by one of the earlier commenters. The standard for a keyboard depends on how it is used. I had a colleague that worked on 60601 approval for a keyboard used in medical applications. For the office, it would be UL 60950-1 or UL 62368-1, with the former standard being withdrawn in late 2020 if I recall correctly. The application in the U.S. is different than in Europe. Products certified to UL 60950-1 can continue to carry the certification mark after the date of withdrawal of the standard. Another date may be set further in the future when UL 60950-1 products would then need to be recertified to UL 62368-1. Keyboards that are USB powered or use alkaline batteries technically fall under the OSHA requirements, but are generally considered low enough power that it is extremely unlikely that an inspector would require them to be NRTL approved. If a keyboard is included in the retail package with an NRTL Listed computer, the NRTL may require the keyboard to be a Listed Accessory. Many NRTLs will require all included electrical accessories to be Listed if they are included in the same SKU with an NRTL Listed product. Ted Eckert Microsoft Corporation The opinions expressed are my own and do not necessarily reflect those of my employer. From: James Pawson (U3C) <ja...@unit3compliance.co.uk <mailto:ja...@unit3compliance.co.uk> > Sent: Tuesday, June 19, 2018 1:56 AM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] UL Listing of Computer Keyboard Hi all, Thanks very much for the illuminating replies, it’s a great help. To summarise (and to make sure I’ve understood): * NRTL approval legally required for selling in the USA? No. * NRTL / UL approval expected? Highly likely. * NRTL approval required for use in the workplace? Yes, not legally required but market expectation? Or is it a legal requirement? * Standard used: UL 62368-1 @Pete Perkins: are you saying when the LVD was recast that they tried to remove the lower voltage limit? Presumably this didn’t happen because companies didn’t want the extra workload involved with extra testing / assessment? Having looked at EN 62368-1, there’s not a great deal in there that applies to a low power device such as a USB powered keyboard so I think it’s fair to say that the type approval wouldn’t take a great deal of time / cost. Reading http://www.productapprovals.co.uk/ul-approval.html <https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.productapprovals.co.uk%2Ful-approval.html&data=02%7C01%7Cted.eckert%40microsoft.com%7C2e125d75d5f34301aba908d5d5c28d35%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636649953933516570&sdata=PsT2iw7EGYBVEVI9oyBGoMJRFyNzLXKp9%2BXwCswulrU%3D&reserved=0> there appear to be initial and regular factory inspections associated with a NRTL listing, with the figure of a few thousand dollars being quoted as a typical fee for maintaining an NRTL mark. Does this match people’s experience? If the factory already has NRTL approval for manufacturing another product, could one piggyback onto this approval or is it on a per product basis? Thanks again James - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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