United States - Machinery and industrial equipment
US compliance requirements for machinery and industrial equipment
Machines and industrial equipment intended primarily for professional use. EU machinery legislation anchors the category; consumer-facing general product safety rules are omitted because these are not consumer products.
For example: benchtop CNC router, conveyor module, industrial mixer, laser engraver.
GPSR/UK GPSR and the US CPSA are omitted because they cover consumer products — but if consumers are reasonably likely to use the machine (e.g. hobby CNC), those regimes re-attach: verify for your product and add the general-consumer rules. Machinery Directive 2006/42/EC applies until 20 January 2027, then Machinery Regulation (EU) 2023/1230 (Annex I lists high-risk machinery needing notified-body assessment). UK: Supply of Machinery (Safety) Regulations 2008 — not a separate id here, verify. Large-scale stationary industrial tools and fixed installations are excluded from RoHS/WEEE — verify whether your equipment qualifies. AI-based safety components in machinery are high-risk AI systems under the EU AI Act — verify (eu-ai-act not auto-applied here). Laser engravers additionally face laser product safety rules (EN 60825; US FDA 21 CFR 1040) — verify. UK PSTI covers consumer connectable products only, so it is not applied. US NRTL listing is mandatory for electrical equipment used in workplaces under OSHA.
Base requirements3 instruments
California law requiring businesses to give a clear and reasonable warning before knowingly and intentionally exposing anyone in California to a chemical on the state's Proposition 65 list, and prohibiting knowing discharges of listed chemicals into drinking water sources. It is a warning law, not a ban — products containing listed chemicals may still be sold if properly warned.
Key obligations
- 01Provide a clear and reasonable warning before knowingly and intentionally exposing anyone in California to a chemical listed under Proposition 65, unless the exposure is low enough to qualify for an exemption.source
- 02Do not knowingly discharge listed chemicals into sources of drinking water in California.source
- 03Track the chemical list: OEHHA maintains the list, which must be updated at least once a year and has grown to include over 800 chemicals (naturally occurring and synthetic) listed for cancer, birth defects or other reproductive harm since first publication in 1987. The current list is dated December 8, 2025.source
- 04Once a chemical is newly listed, businesses have 12 months before the warning requirement takes effect for that chemical.source
Electronic products with digital circuitry that are not designed to transmit radio signals (unintentional radiators) must be authorised before marketing in the US, in most cases via the Supplier's Declaration of Conformity (SDoC): a US-based responsible party tests the product against the FCC emission limits and self-declares compliance, with no FCC filing. Certification through a TCB may be used instead, and is mandatory for a few device types.
Key obligations
- 01Authorise before marketing: except as exempted, unintentional radiators must be authorised via SDoC or certification under 47 CFR Part 2 Subpart J before marketing. The table in 47 CFR 15.101(a) allows "SDoC or Certification" for most device types; scanning receivers, radar detectors and Access BPL equipment require certification.source
- 02Have a US-based responsible party: for SDoC, the party responsible for compliance (the manufacturer or assembler, the importer for imported equipment, or a retailer/OEM that assumes responsibility by agreement) must be located in the United States (47 CFR 2.909(b)).source
- 03Test the device against the applicable technical limits for its class — conducted limits on AC-mains ports are in 47 CFR 15.107 and radiated emission limits in 47 CFR 15.109, with separate limits for Class A and Class B devices (the numeric limits are set out in those sections).source
- 04Supply a compliance information statement with the product at the time of marketing or importation, identifying the product, stating compliance (e.g. the 47 CFR 15.19(a)(3) statement), and giving the name, address and telephone number or internet contact of the US-based responsible party (47 CFR 2.1077).source
NRTL listing (of which UL listing is the best-known example) is product-safety certification by a private laboratory that OSHA has recognised under 29 CFR 1910.7. It is not a general legal requirement for selling consumer goods at retail, but OSHA workplace standards require certain equipment — notably electrical equipment — to be approved by an NRTL, and buyers frequently expect the mark in practice.
Key obligations
- 01OSHA's electrical standard makes conductors and equipment acceptable only if 'approved' (29 CFR 1910.303(a)); under the definitions in 29 CFR 1910.399, an installation or equipment is 'acceptable' (and therefore approved) if it is accepted, certified, listed, labeled or otherwise determined to be safe by a nationally recognized testing laboratory recognised under 29 CFR 1910.7.source
- 02Listed or labeled equipment must be installed and used in accordance with any instructions included in the listing or labeling (29 CFR 1910.303(b)(2)).source
- 03Certification must come from an OSHA-recognised NRTL: an NRTL is an organisation recognised by OSHA that tests for safety and lists, labels or accepts equipment, has the capability to test to appropriate test standards, and is completely independent of the manufacturers, vendors and employers concerned (29 CFR 1910.7(b)).source
- 04NRTL listing involves ongoing surveillance, not just one-time testing: the NRTL must implement procedures for identifying listed equipment, inspect production runs at factories, and conduct field inspections to monitor proper use of its identifying mark or labels (29 CFR 1910.7(b)(2)).source
If your product also...
Extra regulations triggered by specific features
Has radio / wireless (Wi-Fi, Bluetooth, cellular, GPS, RFID/NFC)
FCC Part 15 — Intentional Radiators (Equipment Certification)
Documents you will need
Deduplicated across the regulations above
- Warning label / sign artworkNo certificate or government filing is required; compliance is demonstrated by the warning itself (label, shelf sign/tag, or website warning for internet sales) meeting the content and transmission methods of 27 CCR Article 6.source
- Written notice to retail sellersThe regulations allocate responsibility along the supply chain: manufacturers/suppliers can discharge their duty by providing a warning or a written notice to the retail seller under 27 CCR 25600.2(b) and (c); for internet purchases before January 1, 2028, a retailer is not responsible for posting an updated short-form warning online until 60 calendar days after receiving an updated warning or written notice.source
- Compliance information statementIncluded in the user manual or as a separate sheet supplied with the product (electronic provision permitted under the conditions in 47 CFR 2.1077(c) and 2.935). Must identify the product, state compliance, and identify the US-based responsible party.source
- Test records and description of measurement facilitiesThe testing laboratory must compile a description of the measurement facilities (retained by the party responsible for authorisation and provided to the FCC on request, 47 CFR 2.948(b)); the FCC's OET guidance states the responsible party maintains all documentation demonstrating compliance.source
- Device identification recordsThe responsible party must maintain adequate identification records to facilitate positive identification of each device subject to SDoC (47 CFR 2.1074(a)).source
- NRTL certification (listing) and authorisation to use the NRTL's markIssued by the NRTL, not by OSHA. The NRTL maintains control procedures for identifying listed and labeled equipment, inspects production at factories, and field-inspects use of its mark (29 CFR 1910.7(b)(2)).source
- Listing/labeling instructionsEmployers must install and use listed or labeled equipment in accordance with instructions included in the listing or labeling, so those instructions form part of the compliance documentation (29 CFR 1910.303(b)(2)).source
Frequently asked
Does a Proposition 65 warning mean the product is banned or unsafe?+
No. Prop 65 does not ban any product — it is a right-to-know law. A warning means the business believes the product can expose Californians to a listed chemical above the level where a warning is required (or the business is warning out of caution without measuring exposure).
What counts as an unintentional radiator?+
A device that uses radio-frequency energy internally (for example digital circuitry with clocks above 9 kHz) or sends RF signals over its wiring, but is not designed to transmit radio signals over the air. Most ordinary electronics without a radio — computers, monitors, power supplies, appliances with digital controls — fall in this category.
Is UL listing required by law to sell my product?+
For most consumer goods sold at retail, no federal law requires UL or any NRTL listing. The legal requirement is OSHA's: certain equipment used in workplaces — notably electrical equipment — must be approved, which in practice means certified, listed or labeled by an OSHA-recognised NRTL. Separately, retailers, insurers and local electrical inspectors often insist on an NRTL mark as a commercial condition, so many products are certified even when the law does not demand it.
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