UL Listing required?

In my opinion, their labeling is deceptive and intentionally misleading.
Whole-heartily agree. It states “designed, manufactured and tested to be compliant…” does not mean it is compliant and clearly no mark indicating it was officially tested to be certified to UL.
 
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680.23 Underwater Luminaires. This section covers all luminaires installed below the normal water level of the pool.

(8) Compliance.

Compliance with these requirements shall be obtained by the use of a listed underwater luminaire and by installation of a listed ground-fault circuit interrupter in the branch circuit or a listed transformer for luminaires operating at not more than 15 volts.
 
Article 100 of NFPA 70®, National Electrical Code® (NEC®), defines listing as “equipment, materials, or services included in a list published by an organization that is acceptable to the authority having jurisdiction and concerned with evaluation of products or services, that maintains periodic inspection of production of listed equipment or materials or periodic evaluation of services, and whose listing states that either the equipment, material, or service meets appropriate designated standards or has been tested and found suitable for a specified purpose.”

 
The requirement is that the light be “Listed”, but not necessarily “UL Listed”.

Listed means certified for use in pools or spas by a qualified testing laboratory.

The accepted standard is UL676.

So, any qualified testing laboratory should make sure that the lights at least meet that standard.

So, it’s a bit confusing since the standard is a UL created standard but the test can be carried out by any “qualified” testing laboratory.

If the light is sold for pool or spa use, it should be listed by a qualified testing laboratory and the manufacturer should specify which testing laboratory has certified the light.


The following is the complete list of test standards determined to be appropriate for use under OSHA's NRTL Program.


After certifying a product under the NRTL program, the NRTL authorizes the manufacturer to apply a registered certification mark to the product.

This mark signifies that the NRTL tested and certified the product under the NRTL program, and that the product complies with the requirements of one or more appropriate product safety test standards.

Users of the product can generally rely on the mark as evidence that the product complies with applicable OSHA approval requirement(s) and is safe for use in the workplace.

 
There might be other "qualified" testing laboratories other than the NRTLs.

It really comes down to the AHJ (Authority Having Jurisdiction) whether or not they require a listed product and if they accept the certification from the Testing Laboratory.

Jurisdictions can adopt the NEC as part of their code, but the NEC is not law in and of itself.

If they adopt the NEC, then a listed product is required unless the AHJ deletes that requirement.

The AHJ also decides which testing laboratories are acceptable.

In general, any underwater luminaire for pools or spas should conform to UL676 and be certified and listed by a qualified testing laboratory.

Any manufacturer selling any underwater luminaire for pools or spas should specify which testing laboratory has certified the product.

The United States Consumer Product Safety Commission has a list of approved testing laboratories, but the laboratories each have an “Approved Testing Scope” that defines which standards they are approved to certify.

List of CPSC-Accepted Testing Laboratories

 
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