1. Copyright© 1995-2007 Underwriters Laboratories Inc. All rights reserved. No portion of this material may be reprinted in any form without the express written permission of Underwriters Laboratories Inc. or as otherwise provided in writing. Suppliers Declaration of Conformity: What it Means for Consumers October 26, 2009 Erin Grossi Underwriters Laboratories Consumer Information Panel 2009 International Meeting & Training Symposium

2. p/2 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Agenda 1. Overview of Underwriters Laboratories 2. Basics of Conformity Assessment 3. The Value of Product Certification 4. The SDoC Question: What’s at Stake for Consumers?

3. p/3 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Overview of Underwriters Laboratories Founded in 1894 by William Henry Merrill Private Company 6,800 Employees Across 25 Countries Customers in 98 Countries Standards Developer: Over 1,300 Test and Certify Over 19,000 Types Products To UL and other Private Sector Standards To Government-mandated Requirements 20 Billion Products Carried UL Marks in 2008 Average US home carries 120+ UL-listed products Five Business Lines Product Safety UL Environment UL University UL Life & Health Safety UL Verification Services Consumer Education Partnership with Disney Anticounterfeiting Enforcement Program

4. p/4 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved “ any activity concerned with determining directly or indirectly that relevant requirements are fulfilled ” ISO/IEC Guide 2 Conformity Assessment Defined

5. p/5 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Suppliers’ Declaration of Conformity (SDoC) - Compliance is self-declared by entity “responsible” for the product Testing - conduct specified tests and deliver test results and methods Commercial Inspection and Testing - determine if products meet a purchaser’s/procurement specifications; typically useful if a full quality system is not in place or does not cover key aspects of the product, or if confidence needs of purchaser require inspection in addition to quality management systems Product Certification - basic components: Quality System Registration - incorporates a review of the procedure, an on-site assessment of the implementation of the procedure, and audits to verify continued implementation and to identify areas that could be improved Types of Conformity Assessment  investigation: includes testing, comparing them to requirements, and determining compliance  surveillance: includes among other things, unannounced and frequent product inspections, witnessing of production

6. p/6 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Product Certification Process Consensus Standards Industry Consumers Authorities Academics Certifiers Interested Parties Threshold for Safety Pre-Market Assessment and Certification Verification of Conformity to the Standard Factory Pre-Inspection & Approval Ensuring Safety entering the market Ongoing Factory Surveillance Verification That Product “As-Built” Conforms to the Approval Avoid Adulteration Post Market Surveillance Random Purchase @ Retail and Verification Testing Anti-Counterfeiting Communication with CPSC Monitor Real- Life Outcomes Recipe for maintaining “Integrity & Trust” in a time-tested Safety Certification Program

7. p/7 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Value of Product Certification: Consumer Perspective “Closed Loop System” Ensures On-going Compliance Across Global Supply Chain Independent Product Review Balances Safety and Trade Certification Creates an Even Playing Field for All Manufacturers Certifier Polices Market for Non-compliant and Counterfeit Products Certification Feeds Back Valuable Information to Standards Development Process

8. p/8 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved “SDoC” Challenges 2005 Request for OSHA RFI on SDoC 2008 Request for OSHA RFI on SDoC WTO Non-Agricultural Market Access Negotiation Proposal EU-Korea FTA [Led to Increased SDoC Acceptance for Electrical Products in Korea] SDoC Outreach in Saudi Arabia, India, ASEAN and other Emerging Markets

9. p/9 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Supplier’s Declaration of Conformity – The Drivers Elite IT companies (e.g. HP, Dell, Siemens, etc.) Information Technology Industry Council (ITI) European Commission officials (DG Trade and DG Enterprise) Elite IT Companies European Commission Information Technology Industry Council (ITI)

10. p/10 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Highlights of EC 2008 Request for OSHA RFI on SDoC EC Claims IT and Electrical Equipment rated up to 1000 V AC (1500 DC) has a low risk of noncompliance resulting in low safety risk EC Contends NRTL requirements create transatlantic trade imbalance and lack of market access for European certifiers in the US market EC believes European consumers enjoy a high if not higher level of electrical safety than counterparts in the US under SDoC EC contends there is no association between product non-compliances and product incidents in the EU EC raises cost issues and indicates NRTL requirements cost EU exporters 1.3 Billion Euros annually

11. p/11 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Highlights of UL’s Response to RFI: The Rebuttals Products Less Than 1500 V Do Pose Significant Safety Risks [Scope Too Broad] Regulators Have the Established Right to Choose CA Mechanism As Long As Requirements Are Applied Equally to Domestic and International Entities NRTL Program Balances Trade and Safety Concerns EC Studies and Reports from European Consumers and Safety Experts Demonstrate Imperfections of SDoC System Product Noncompliance IS an Issue With Safety Ramifications in Europe Costs of Third-party Certification are Not Overly Burdensome

12. p/12 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Why Should Consumers Care? What’s at Stake? Potential Loss of Regulatory Drivers of Certification First Pass Fail Rates Suggest Noncompliance Would Increase Under SDoC Lack of FUS – What Happens Over-Time? Challenges of Global Supply Chain Components Issues: Unseen Dangers Demise of a Key Link in Evolutionary Process of Product Safety

13. p/13 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved Consumer Organizations Engaging in SDoC Debate Consumers Union ANEC & BEUC in Europe National Consumers League EU Consumer Advocacy GroupsNational Consumers League Consumers Union

14. p/14 Copyright © 2008 Underwriters Laboratories Inc. ® All rights reserved What Can You Do to Weigh In on SDoC? Join Third-Party Certification Coalition, Organized by the National Electrical Manufacturers Association (NEMA) Register With UL as a Third-Party Supporter and We Will Alert You When There are Opportunities to Comment in SDoC Debates

15. Copyright© 1995-2007 Underwriters Laboratories Inc. All rights reserved. No portion of this material may be reprinted in any form without the express written permission of Underwriters Laboratories Inc. or as otherwise provided in writing. Thank You Contact: Erin Grossi | (202) 296-7841 | erin.grossi@us.ul.com