Positioning of the guide: A bridge connecting protocols and actual operations
The core objective of UL's launch of the "Guide to the Follow-up Service Agreement" is to help customers break the deadlock of "agreement = legal document = put aside". For most customers, the "Follow-up Service Agreement" is a legally binding official text that is often filed and rarely actively consulted. However, the guide was designed with a completely different intention - it uses straightforward and non-legal language to break down high-frequency questions such as "how to set up the follow-up service" and "how to cooperate in daily implementation". It is an "operating manual" that customers can refer to at any time in their daily work.
It should be clearly noted that the guide is only used for explanation and auxiliary understanding and can never replace the legal effect of the agreement itself. The agreement is the ultimate basis for the rights and obligations of UL and the customer. For issues not covered by the guide (such as the application of terms in special scenarios), the provisions of the agreement shall still prevail. If the customer has questions not answered by the guide, the most effective solution is to directly contact the representative of the UL follow - up service agency.
Core nouns in the agreement: Clarify the roles and service boundaries
UL delineates the roles and service types of all parties through clear noun definitions to avoid ambiguities in implementation.
1. Three types of customer roles
Applicant: The initiator who requests UL to conduct inspections on products, components, or devices (which can be an enterprise or an individual), and is the starter of the certification process.
Manufacturer: The location where the product is actually produced, assembled, or affixed with the UL mark (i.e., the responsible site verified on - site by UL inspectors). Note: The core obligation of the manufacturer is to produce in compliance at the designated location. If the production location is changed without prior notice to UL, it directly constitutes a breach of contract.
Listed Party: The entity whose name is included in the UL Product Directory (it is the key basis for consumers to inquire whether a product has passed UL certification).
2. Subscriber: The party signing the agreement
A subscriber is a party that signs the Follow-up Service Agreement with UL and can be composed of any one or a combination of multiple parties among the applicant, the manufacturer, and the listed party (for example, an enterprise may be both the "applicant" (initiating the inspection by itself) and the "manufacturer" (producing by itself). In this case, it only needs to sign the agreement as a single "subscriber"). Before the follow-up service starts, the applicant, the manufacturer, and the listed party need to sign the agreement respectively (if the roles overlap, a consolidated signature is required).
3. Three types of service categories
UL's service types directly correspond to the certification requirements of products.
Listing service: It is applicable to finished products (such as household appliances and electronic devices) and is the most common type of certification.
Classification Service (Classification): For specific categories of products (such as building materials and fire - fighting equipment), emphasize the certification of "classification attribution".
Recognition: It only applies to components (such as circuit board capacitors and connectors), and focuses on "component-level compliance".
UL will directly inform customers which type of service they need according to the product type. For example, customers who produce household appliances usually apply for the "Listing Service", while those who produce electronic components apply for the "Recognition Service".
Inspection rules: The "operation bible" for follow-up inspections
The "Inspection Rules" is the core implementation document provided by UL to manufacturers, equivalent to the "cooperation manual" for both parties. Its content directly determines "what can be done and what cannot be done":
Define the product scope: Specify which models/specifications of products are eligible to use the UL mark (products not listed in the detailed rules cannot be labeled, even if they have a similar appearance).
Standardize manufacturing requirements: Provide a detailed description of the compliance standards for the production process (such as raw material specifications, process parameters, and quality control procedures).
Define the marking rules: Specify the type of UL mark to be used (such as printed labels or molded marks) and the attachment position (it must be firm and clear to avoid falling off).
Define the obligations of both parties: On the one hand, require manufacturers to "carry out production in accordance with the detailed rules and keep production records"; on the other hand, clarify the on - site work content of UL inspectors (such as verifying whether the production process complies with regulations and whether the use of marks meets the requirements).
The consequences of violating the "Inspection Rules" are direct and clear - any act that fails to comply with the rules (such as changing the production location without notifying UL or using non - rule - stipulated marks) is regarded as a breach of the agreement. Therefore, if customers have plans to change the production process, location, or product design, they must notify UL in advance to avoid service interruption due to "breach of contract".
The essence of the UL mark: "Separation of ownership and right of use" of public credibility
The ownership of the UL mark always belongs to UL - this is one of the core principles of the agreement. Even if a customer signs the agreement and pays the inspection or follow - up inspection fees, they only obtain "the right to use the mark under compliant circumstances", not the ownership of the mark.
The reason why UL retains the ownership of the mark is very clear: the mark is the carrier of the credibility of UL certification, and its value lies in "consumers' trust in UL certification". UL must maintain its "compliance and consistency" by strictly controlling the use of the mark. For example, if customers are allowed to modify the mark style at will or expand the scope of use, the credibility of the mark will be diluted, ultimately harming the interests of all customers.
"Red lines" for logo use: Compliance is the sole prerequisite
The use of the logo must strictly follow the dual standards of "detailed regulations + agreement requirements". The specific rules can be divided into two categories:
1. Use of logos on products
Type and location: It must be consistent with the provisions of the Inspection Rules. (For example, if the rules require that "the label should be pasted on the back of the product", it cannot be pasted on the side; if it requires "using a molded label", a printed label cannot be used.)
Validity conditions: The mark can only be used when the product meets the production requirements of the "Inspection Rules" and is within the validity period of the follow-up inspection service. If the product is judged not to meet UL requirements, or the customer violates the terms of the agreement, the right to use the mark will be automatically terminated.
2. Use of logos in advertising and publicity
Prohibition of Misleading: The UL name or logo can be cited (e.g., "This product is UL - listed", "This component is UL - recognized"), but misleading statements such as "UL recommends this product" or "This product is the top - level in the industry" are not allowed.
Special requirements for classified services: If the product belongs to classified services, the complete content of the classification mark must be quoted in the advertisement (for example, if the detailed rules stipulate that "the classification mark is 'UL Classified Fire - Resistant Door', it cannot be simplified to 'UL Classified Door').
Principle of prior confirmation: If a customer plans to use the UL name or logo in an advertisement, it is best to communicate with the UL inspection representative first. UL may require the modification of improper expressions (for example, changing "UL top - level certification" to "UL - listed products"). Prior confirmation can avoid the waste of revoking the advertisement later.
"Approval and Purchase" of logo labels: Control compliance from the source
Labels with the UL mark must be produced by UL-authorized printers – this is a crucial step in ensuring the consistency of the mark.
The role of the authorized printer: UL will sign a contract with the printer, requiring it to print labels strictly in accordance with the provisions of the "Inspection Rules" (such as the size, color, and font of the logo) to ensure that the styles of all labels are completely the same.
Requirements for custom printers: If a customer wishes to use a printer of their own choice, the printer must first obtain authorization from UL (UL will verify its printing capabilities and compliance).
Retention of ownership of labels: Even if the customer has paid the label printing fees, UL still retains the ownership of the unused labels. If UL discovers that the customer uses the labels in a non - permitted manner (for example, pasting the labels on products not specified in the regulations), UL has the right to require the customer to return all the unused labels.
Core responsibilities of subscribers: "Self-verification" is the foundation for continuous compliance
The customer's responsibility is by no means as simple as "waiting for UL inspection." The agreement requires the customer to establish an internal production inspection and testing system and proactively ensure that the products meet UL requirements.
Daily verification obligation: Achieve "compliance of each batch of products" through incoming inspection (verifying whether raw materials meet UL standards), process inspection (monitoring whether the production process is compliant), and finished product testing (confirming that product performance meets UL requirements).
Record retention requirements: All inspection and test records (such as raw material qualification certificates, production process parameters, and finished product test reports) need to be retained for on - site verification by UL inspectors.
Declaration obligation: When a customer uses the UL mark, it is equivalent to making a declaration to the market that "the product meets UL requirements". If the product fails to meet the requirements due to the customer's own reasons (such as substituting raw materials), the customer shall bear the corresponding legal liability.
Simply put, UL's follow-up inspection is a "sampling inspection," while the customer's "self-verification" is a "full-process guarantee" — only when the customer actively implements internal control can the follow-up inspection service truly play its role in "continuous compliance."
The above is the breakdown of the core content of the Follow-Up Services Agreement. In essence, all the rules of the agreement revolve around one goal: to ensure that the customer's products continuously comply with UL standards through clear division of rights and obligations, and at the same time maintain the credibility of the UL Mark. For customers, understanding and complying with these rules is not only a requirement for fulfilling the agreement, but also the key to enhancing product competitiveness with the help of UL certification.
Obligation of immediate notification of product compliance and disaster events
After the products with the UL mark leave the factory, if an enterprise finds that they are not manufactured in strict accordance with UL requirements or learns that the products are involved in disaster events (such as causing safety accidents like fires or electric shocks), it must notify UL immediately. This obligation is a core part of ensuring product safety traceability. If UL learns through third - party channels (such as consumer complaints, notifications from regulatory authorities, or market spot checks) that the products are non - compliant or dangerous, the enterprise must fully cooperate with UL's investigation: this includes providing production batch records, raw material procurement vouchers, quality inspection reports and other materials to assist UL in restoring the truth. It should be emphasized that any corrective actions taken by the enterprise regarding the problematic products (even a full - scale market recall) must be simultaneously notified to UL. UL needs to keep track of the progress of risk handling to assess whether further intervention in public warnings or regulatory communication is required.
Routine process of follow-up inspection and requirements for enterprise cooperation
During the validity period of the "Follow-up Inspection Service Agreement", UL inspection representatives will regularly visit the factory (the frequency is adjusted according to the product risk level) to conduct full - process inspection and testing on the products. The scope of inspection covers all places related to product production, such as component manufacturing workshops, finished product assembly lines, and storage warehouses. UL representatives have the right to freely enter these areas, and the enterprise shall not require them to sign any legal documents (such as "Confidentiality Agreement" or "Disclaimer") in exchange for entry permission (however, UL will require representatives to comply with the factory's safety regulations, such as wearing labor protection supplies and registering visitor information).
Enterprises are required to fulfill two basic obligations:
1. Site and equipment support: Ensure that the factory environment meets the requirements of the "Inspection Rules" (e.g., the production workshop is tidy and the test equipment is effectively calibrated), and provide sufficient space and tools for UL to conduct on - site tests. If the "Inspection Rules" require improvements (e.g., adding electrostatic protection facilities), the enterprise shall make timely adjustments.
2. Management of marks and products: Properly store UL marks, labels, and marked products (e.g., store them separately and keep a record of issuance and receipt), which facilitates the inspection representatives to verify the usage of marks (e.g., whether the marks are affixed beyond the scope) and the compliance of products.
The core responsibility of an enterprise: The final determination of product compliance
A key principle needs to be clarified: The enterprise is the primary responsible party for the UL compliance of products. UL's follow - up inspection is a "supervision measure" rather than an "alternative liability". Even if the products pass UL's regular spot checks, the enterprise still needs to ensure that each product leaving the factory complies with UL standards through its own quality control system (such as incoming inspection of raw materials, control of process SOPs, and full inspection of finished products). For example, if an enterprise replaces a certain key component (such as the power cord supplier), even if the component is a "UL recognized part", the enterprise still needs to verify its compatibility with the finished product to ensure that the overall product meets UL requirements. This verification responsibility lies with the enterprise, not UL.
Rules for Handling Discrepant Inspections and Filing Appeals
If the UL inspection shows that the products do not meet UL requirements on site (e.g., insufficient insulation thickness, non - compliant fire - resistance rating), the enterprise shall immediately take one of the following actions:
Correct non - compliant items: Rectify the products (such as replacing qualified components and adjusting production parameters) in the presence or with the confirmation of the inspection representative.
Remove the UL mark: Tear off or cover all the UL marks on the non-compliant products specified by the inspection representative.
If an enterprise has objections to the inspection results, it can submit an appeal to the corresponding follow-up inspection service manager (written evidence such as third-party test reports and process change records needs to be provided). However, during the appeal period, it is strictly prohibited to continue shipping products with the UL mark. Even if the enterprise believes that the products are "actually compliant", the mark shall not be used continuously before obtaining written consent from UL. The purpose of this rule is to prevent non-compliant products from entering the market and damaging UL's brand credibility.
Legal consequences of misusing the UL mark
Misusing the UL mark is a red line that enterprises need to avoid, and the specific scenarios include:
1. Affix the UL mark to non-UL listed/recognized products (e.g., a new model of socket produced by an enterprise that has not passed UL inspection but has the UL mark of an old model affixed to it).
2. The listed products fail to meet the UL standards or the requirements of the "Inspection Rules" (for example, continuing to use the logo when the flame retardancy fails to meet the standard due to the reduction of raw material grades).
3. The product is manufactured by a manufacturer or factory not recognized by UL (for example, an enterprise outsources production to a contract manufacturer that has not passed the UL audit but allows the contract manufacturer to affix the UL mark).
In the event of misuse, UL reserves the right to take legal action.
- Apply to the court for a temporary or permanent injunction to prohibit the enterprise from selling, transporting or distributing products with the UL mark.
- Seek monetary compensation (including direct losses and punitive damages).
At the same time, the enterprise is required to assume the responsibility of "indemnifying UL against losses": If UL is sued by a third party due to misuse (for example, consumers sue UL because of product accidents), or UL incurs expenses to stop the misuse (such as attorney's fees and investigation fees), the enterprise shall fully compensate UL for all losses - this clause covers all legal risks that UL may face.
Compliance requirements after the revision of UL standards
UL will revise product standards based on technological advancements or safety requirements (such as the newly added over - charge protection requirements for lithium - battery products) and notify enterprises in writing of the effective date of the new standards. Enterprises need to complete three tasks before the effective date:
1. Evaluate existing products: Check whether the products meet the new standards (e.g., whether the old chargers lack an overcharge protection circuit).
2. Product improvement: If it does not meet the requirements, the design needs to be modified (e.g., adding a protection circuit) or the materials need to be replaced.
3. Send the product for UL inspection: Send the improved product to the UL laboratory for testing. Only after passing the inspection can the enterprise continue to use the UL mark after the new standard comes into effect.
If the enterprise fails to submit products for inspection before the effective date, or the submitted products fail the inspection, the right to use the UL mark will be automatically forfeited as of the effective date. Please note that the inspection process for improved products is the same as that for "new product submission for inspection", and UL will charge fees (such as testing fees and labor fees) according to the current rates.
Circumstances and Consequences of Agreement Termination
1. Immediate termination: If the enterprise fails to fulfill any obligation under the agreement (e.g., fails to pay the fees within 30 days after the due date, or refuses to allow UL representatives to enter the factory), UL may immediately terminate its right to use the mark and notify third - parties (such as distributors, regulatory authorities, and consumers) to prevent non - compliant products from continuing to circulate.
2. Termination with 30-day advance notice: If an enterprise fails to use UL marks on a certain type of product for two consecutive calendar years (for example, the enterprise has stopped producing a certain type of lamp for more than two years), or encounters serious economic difficulties (for example, being unable to maintain production due to bankruptcy and reorganization), UL will notify the enterprise in writing 30 days in advance to terminate the services for the corresponding products.
3. Termination with 60-day advance notice: Either the enterprise or UL may terminate the agreement (either for a single category of products or for all products) by giving a 60-day advance notice in a registered letter for any reason (such as the enterprise's transformation and no longer producing such products, or UL's adjustment of its business scope).
After termination, the enterprise shall immediately cease:
- Use the UL mark on products, packaging or in promotions, or refer to the UL name (e.g., claim in advertisements that "This product is UL certified").
- Pay all service fees incurred before the termination date of payment (even if the service is not completed).
UL's Public Warnings and Confidentiality Obligations
As an independent third - party organization, UL needs to balance "public safety" and "corporate confidentiality".
Public warning right: If a product poses an extreme danger (for example, a certain type of electric heater may explode due to a short - circuit and the risk cannot be eliminated through simple rectification), UL can directly issue warnings to the public (such as through its official website and media announcements) without the consent of the enterprise. This is UL's legal responsibility to ensure consumer safety.
Confidentiality obligation: UL will not take the initiative to disclose the confidential information provided by the enterprise (such as unpublicized production processes and patented technologies) to third parties, unless the information is already known to the public or the industry (for example, the enterprise has made the process public at an exhibition), or it must be disclosed due to public safety concerns (such as product accidents caused by process defects).
Charging Standards and Payment Requirements
UL's service fees are determined based on the nature and scope of the services (for example, the monthly inspection fee for high-risk products is higher than that for low-risk products) and are charged at the currently effective rates. When the rates are adjusted, UL will notify the enterprises in writing in advance.
Trigger scenarios for additional fees:
1. Additional inspections caused by non-compliance of the enterprise: If an enterprise requires UL representatives to conduct repeated inspections due to its products failing to meet the requirements multiple times, the enterprise shall bear the additional labor costs incurred.
2. Inadequate enterprise control: For example, the enterprise's quality control process is in a mess (e.g., there are no raw material inspection records). UL needs to increase the inspection frequency, and the additional costs incurred shall be borne by the enterprise.
All invoices shall be paid within 30 days after issuance. Failure to pay on time will be regarded as "breach of obligation", and UL reserves the right to suspend or terminate the services.
Non - assignability of rights clause
This agreement represents an exclusive relationship between the enterprise and UL. Without the written consent of UL, the enterprise shall not assign any rights under this agreement (such as the right to use the logo and the right to apply for inspection) to third - parties (including subsidiaries, distributors, and bankruptcy receivers). If the enterprise assigns the rights without permission (for example, sells the rights under the agreement to another factory), UL shall not assume any legal responsibility towards the third - party. The third - party cannot require UL to provide services or recognize its products on the grounds of "acquiring the agreement".