UL Updates Label Requirements for Lighting Products

February 1, 2022 Update: The label deadline has passed

Please note that the extended Dec. 31, 2021 deadline to switch from holographic labels to the Enhanced Mark labels on lighting products has now passed. Lighting products should now be labeled using the newly designed mark being printed in-house or purchased from UL authorized label suppliers. 

Before your next inspection, make sure your labels have been updated. See below for information on how to proceed if you still need to make this change.

Changing label requirements

When your products have earned the UL Mark, you want the world to know it; the authorization to apply a UL Mark label to a product is a critical piece of the certification process. We’ve listened to lighting industry feedback and are implementing a simplified approach to labeling.

For those lighting products that use labels that include an issue, lot or serial number or holographic labels, customers can now enjoy the flexibility and control they desire at a lower cost as UL moves to the use of a non-holographic label for luminaires.

What is changing?

UL will be phasing out holographic labels and certain other types that are currently ordered through a UL Label Center for lighting manufacturers in 2021 and moving to a non-holographic label employing an enhanced mark (approved through our UL Marks Hub) in its place.

• Instead of having to order lighting labels through UL, you can either print your UL Mark labels directly within your facility or purchase directly from an authorized label supplier.
• Enjoy the benefit of no annual label fee from UL through self-printing your labels, or you may purchase labels directly from a UL authorized label supplier.

Click here to see if your products fall under the assigned CCN list. All CCNs on this list will fall under the new label requirements starting in 2021.

Holographic labels are serialized requiring UL to collaborate on the printing of each label batch. Switching the lighting categories to non-holographic labels using the newer Enhanced and Smart UL Certification Marks allows customers to print or procure labels after a one-time artwork approval instead of requiring collaboration with the UL Label Center for each batch of labels. In addition, the use of our optional promotional badges will deliver greater transparency into the UL certifications your products have achieved. Click here for more information on our enhanced marks.

Please click here for guidance on our advertising requirements.

While some certification bodies charge an annual fee for the ability to print certification labels, UL is pleased to allow manufacturers the ability to print their lighting labels with no annual label fee. The retirement of holographic labels will also allow lighting customers to label all of their UL Certified lighting products on standard paper labels, delivering a more uniform and simple experience.

How do the new printing choices work?

• Printing your own labels at your facility gives you more flexibility and allows you to direct print without label order delays. If you decide to print your own UL mark labels at your manufacturing facility, our Marks Hub will guide you to design the appropriate UL Mark artwork. All you need to get started is your file number, or project number and product CCN – the Marks Hub requires a registration but is free to use.
  • Step 1: UL Mark design. Visit our Marks Hub to design your Mark. Here you will get your Label artwork approval. Get a one-time stamped approval from our UL Label Center. You can submit your artwork review request here. 
  • Step 2: begin printing labels from your authorized manufacturing location.
• Ordering labels from an authorized label supplier makes reordering labels simple
  • Step 1: Same as above
  • Step 2: Search for a local authorized printer through our UL Product iQ™ directory. Search “PGAA” to see a list of authorized printers or narrow your search by geographic location. All UL customers have access to free registration with the UL Product iQ database.

Keep reading to learn more about how this label migration will take place, and the timing of the change.

Why is UL making this change? Why now?

We recognize that lighting manufacturers appreciate the added flexibility and control over their product labeling, as well as lower out of pocket costs.

While holographic labels have served the lighting industry as an effective anti-counterfeiting tool, we believe that the timing is right to transition to non-holographic labels. UL’s brand protection team will remain actively engaged with our clients, law enforcement and customs agencies around the world to address and respond to counterfeiting complaints.

UL enhanced labels offer transparency for authorities, buyers, retailers and consumers with fast access or confirmation of certification details. Each UL certification mark indicates product attributes, service description, country code, file number and an optional QR code that leads to a UL-hosted certification page. Click here to learn more about Mark designs.

What is the timeline for this change, and what should be done with spare labels?

The changeover will begin Jan. 1, 2021. UL will continue to offer the old labels to lighting manufacturers until stock is depleted.

Please note that labels that you may have in stock can be utilized through Dec. 31, 2021 on products; as of Jan. 1, 2022, the new label requirements will be in effect and old labels can no longer be accepted on products. We recently extended the deadline date, but encourage all customers not to order too much inventory in anticipation of this change and begin depleting existing stock immediately. We also encourage customers to set up their new enhanced label artwork as soon as possible in anticipation of switching to printing at their facility or using an authorized printer.

A longer transition period for packaging and marketing materials will allow the existing mark to be utilized through Dec. 31, 2022.

Migration Timeline

UL will send you communications to remind you of these key steps in the label migration.

1. Dec. 1, 2020 – UL announces plans to retire certain labels, including holographic labels, for lighting products.
2. Jan. 1, 2021 – The luminaire label change goes into effect. Manufacturers are encouraged to make plans to design UL Mark labels to be printed in house or purchased from UL authorized label suppliers as soon as possible. UL will process orders for the old product labels until inventory is depleted. Any old labels customers have in stock can still be used until June 30, 2021 . We encourage all customers to begin preparing to switch as soon as possible.
3. Throughout 2021 – lighting manufacturers should deplete their existing stock of labels and prepare to print the new labels at their facility or order them through an authorized printer.
4. Dec. 31, 2021 – After this date the old labels will be discontinued. Lighting products will be labeled using the newly designed mark being printed in house or purchased from UL authorized label suppliers. Customers should work with their local field engineer to handle any labels that are not used by the expiration date. 
5. Dec. 31, 2022 – Provisions for references to the UL Marks being retired on product packaging and marketing materials will be discontinued and only the enhanced Mark and badge should be used.

We’re here to support you; contact us for questions and help getting started.

FAQs

Q. What action should I be taking at this time?

A. Start with taking an inventory of your holographic and serialized (Type L) label stocks for the product categories covered by the bulletin. This will help you determine a schedule for depleting them by the extended Dec. 31, 2021, effective date. Going forward you will need to decide if you want to print labels at your authorized factories or order them through a UL label supplier. Follow the instructions provided on this page for the necessary steps that must be completed before you print or order your first batch of labels. We recommend that you keep any future orders of holographic or serialized (Type L) labels to minimal quantities, just enough to carry you through while your company transitions to the new labels. Please note that holographic or serialized (Type L) labels cannot be used in production on or after the Dec. 31, 2021 cut-off date.

Q. Am I going to need to apply for permanent issue numbers like I do for some of our other CCNs before I print labels in the plants?

A. No, you will not have to apply for a permanent issue number. You will use the Enhanced UL Mark with your file number on the new labels.

Q. Are there going to be audits of the printing equipment to ensure that recognized printers, label stock and ink are being used? 

A. No, there are no material requirements for printing the UL Mark at your factory. However, if the UL Mark is integrated into a label with markings required by a specific UL Standard, then the label would need to meet applicable material and print requirements in your UL Follow-Up Services procedure.

Q. Can the new label marking be molded or laser etched into the product?

A. Yes, the Enhanced Mark can be molded or etched, but the Smart Mark cannot be molded or etched directly on the product. Please visit https://markshub.ul.com/ for more information or assistance with your Mark printing needs.

Q. Can I begin to apply the new promotional badge on the packaging of my certified products while I continue to use up my remaining inventory of holographic labels until Dec. 31, 2021?

A: The promotional badge on packaging is intended to be used in combination with products bearing the Enhanced UL Mark. However, during the transition period ending on Dec. 31, 2021, the promotional badge may appear on the packaging of certified lighting products bearing either the legacy (holographic) UL Mark or the Enhanced Mark.