North American Certification and Compliance for Electrical Products: A Technical Guide

Getting electrical and electronic products into the US and Canadian markets means dealing with multiple regulators, mandatory third-party certification, and requirements that vary by product type, end use, and jurisdiction. This guide sets out what applies, to what, and who is responsible for each part of the process.

This whitepaper, authored by Element’s Connected Technologies experts — Simon Barrowcliff, Bob Burek, Andy Smith, and David Schaefer — sets out how the regulatory system actually works, where projects most often run into trouble, and how to structure a single test program that addresses both US and Canadian requirements while feeding into a wider Global Market Access strategy.

 

What You Will Learn About North American Certification

This whitepaper is for electrical and electronic product manufacturers preparing to certify products for the US and Canadian markets. Download it if any of the following apply to your program:

• Your products are CE marked or ATEX certified, and you are entering North America for the first time.
• You are managing US and Canadian certification as a single workstream and have not yet accounted for the structural differences between NRTL and SCC requirements.
• Your bill of materials has not been checked for component recognition status ahead of safety certification.
• You are unsure whether your product requires FCC Certification through a TCB or qualifies for the SDoC route under Part 15 Subpart B.
• Your wireless product operates in Canada, and you need to confirm compliance with RSS-247 Issue 4 and RSS-102 Issue 6.
• Your product is destined for a hazardous location, and you need to understand where ATEX or IECEx evidence transfers and where it does not.
• You want to structure your North American program around the IECEE CB Scheme to avoid duplicate testing across multiple markets.

 

Why North American market access is more complicated than most teams expect

For products coming from Europe — or being launched into multiple markets simultaneously — North America represents a structural shift in how compliance works. The EU model is built around CE marking and self-declaration: one mark, a unified market, and the manufacturer’s own assessment as the default acceptance route for most product categories. North America operates on the opposite logic. Almost every electrical product requires third-party certification, mandated by a different agency depending on the product and its intended use. CE marking is not accepted as a substitute. ATEX certification is not accepted in classified locations. EU self-declarations carry no weight before OSHA, the FCC, the SCC, or ISED.

The complexity sits in the seams between regulators. NRTL certification (US) and SCC certification (Canada) both rely on mandatory third-party certification, but apply different standards and different ongoing obligations. FCC and ISED both regulate radio and EMC, but use different category structures and impose different RF exposure thresholds. Most schedule slippage in North American programs traces back to assumptions carried over from a single-market mental model — and those assumptions usually surface late, when design freeze has already removed the cheaper options.

 

What you will learn from the whitepaper

The whitepaper is a practical, regulator-by-regulator guide to certifying electrical and electronic products for the US and Canada. It covers:

• The North American compliance map — who regulates what, and where the US and Canadian structures diverge from the EU.
• OSHA’s NRTL program under 29 CFR 1910.7, the four-stage certification process, and the ongoing surveillance obligations.
• SCC accreditation, the Canadian Electrical Code, and the SPE-1000 special inspection route.
• FCC SDoC vs Certification through a TCB, multi-radio intermodulation testing, and RF exposure under §2.1091/2.1093 with KDB 447498.
• ISED Category I vs Category II radio equipment, RSS-247 Issue 4, RSS-102 Issue 6, and ICES-003 Issue 7.
• FDA premarket pathways (510(k), De Novo, PMA), the QMSR final rule, the ASCA program, and Health Canada’s Medical Device License framework under SOR/98-282.
• Hazardous Locations — Class/Division vs Zone classification, and where ATEX or IECEx evidence does and does not transfer.
• The IECEE CB Scheme is the most efficient route to a coordinated multi-market program.
• The seven recurring pitfalls that cause schedule and budget slippage, with practical guidance on avoiding them.

 

Excerpt from the whitepaper

“One of the seven pitfalls covered in the whitepaper: manufacturers select components without checking recognition status, then discover at the certification stage that an unrecognized power supply or transformer stalls the entire program. The fix is straightforward. Build component recognition into the bill of materials at the concept stage, before design decisions are locked.”

 

The NRTL certification process

OSHA’s Nationally Recognized Testing Laboratory (NRTL) program, defined under 29 CFR 1910.7, is the cornerstone of US electrical safety certification. Any OSHA-recognized NRTL — Element among them — can certify products against the applicable UL, ANSI, or IEC-derived standards within their accredited scope. OSHA treats all recognized NRTLs as equivalent, so the choice of laboratory is generally driven by responsiveness, geographic coverage, and whether they can combine safety, EMC, and wireless work in a single program.

The NRTL certification process covers four areas:

• Construction review and component traceability — a physical inspection against the construction requirements of the target standard, including enclosure design, board-level spacings, and the recognition status of safety-critical components.
• Type testing — dielectric, temperature, abnormal condition, flame, and mechanical tests as defined by the standard.
• Labeling and user documentation compliance — verification that markings, ratings, and user documentation meet the standard’s requirements.
• Follow-up services — unannounced factory inspections and a formal variation control process for any change to the certified product.

The fourth area is where many programs underestimate the ongoing commitment. Any change to a certified product — hardware, components, materials, or supplier — must be reviewed by the NRTL before it is implemented. Manufacturers who treat the certificate as a milestone rather than a live program risk losing their listing, and with it, market access.

 

Regional differences: United States vs Canada

Although both countries rely on mandatory third-party certification, the systems are structurally different. The US NRTL program primarily covers electrical equipment used in the workplace — although market expectations mean most consumer and commercial products carry an NRTL mark regardless. Canada’s SCC program is broader: every electrical product placed on the Canadian market, regardless of where it is used, requires SCC-accredited certification to standards accepted under the Canadian Electrical Code.

 

The applicable standards diverge as well. The US works primarily with UL and ANSI standards; Canada works with the CSA C22.2 series and IEC-derived adoptions. Many product categories now have aligned binational standards, which makes a coordinated test program more efficient than running two separate ones — but the certification marks themselves remain distinct, and a single NRTL listing does not satisfy SCC requirements. Field-level differences also matter: the US allows field labeling for one-off equipment, while Canada provides the SPE-1000 special inspection path with its own scope and category exclusions. Bilingual labeling in English and French is a Canadian requirement under CSA standards and provincial regulations, and needs to be designed in from the outset.

 

Electrical product safety, EMC, and wireless testing considerations

A coordinated North American test program typically addresses three workstreams in parallel — safety certification, EMC compliance, and radio/wireless authorization. Each carries its own decision points, and timing them correctly is what separates a single-pass program from one that hits late-stage retesting.

For electrical product safety, the most consequential early decision is critical-component selection. NRTL and SCC certifications both extend to the components inside the product, not just the finished assembly. An unrecognized power supply, transformer, connector, or capacitor can stall a program regardless of how well the rest of the design is executed. Building component recognition into the bill of materials at the concept stage is the single most reliable schedule control available.

For EMC, the FCC SDoC vs Certification determination is the first decision and the most commonly mistimed one. Products with no intentional radiator can use the SDoC route under Part 15 Subpart B; products containing an intentional radiator require Certification through a Telecommunications Certification Body (TCB). Products with multiple integrated radios capable of simultaneous transmission also require an intermodulation investigation, which depends on antenna proximity and frequency separation — both of which become difficult to change once hardware is frozen.

For wireless, RF exposure compliance is where many products encounter unexpected difficulty. Mobile devices used at 20 cm or greater are evaluated under FCC §2.1091 (Maximum Permissible Exposure); portable devices used closer than 20 cm fall under §2.1093 (Specific Absorption Rate). KDB 447498 standardizes body-separation assumptions, typically 5 mm for body-worn devices. In Canada, RSS-102 Issue 6 — mandatory since December 2024 — introduced revised SAR exemptions and updated requirements for sub-10 MHz and millimeter-wave applications. RSS-247 Issue 4, with a transition deadline of January 2026, brought further changes for 2.4 GHz, 5 GHz, and 902–928 MHz equipment.

 

The IECEE CB Scheme as a global market access strategy

The fundamental safety standards used by North American certification bodies — UL 62368-1, CSA C22.2 No. 62368-1, IEC 60601-1, IEC 61010-1, and others — are national adoptions of IEC standards that sit at the core of the IECEE CB Scheme. The differences are limited to national deviations covering local installation rules. A CB Test Report structured to include US and Canadian deviations from the outset can form the technical basis for both NRTL and SCC certification, while remaining valid across the 50+ other CB Scheme countries. The whitepaper explains how to design a program around the CB Scheme from the start, rather than retrofit it after the fact.

 

Download the whitepaper below for the complete regulatory maps, standards-by-product-category tables, and the structured workflow Element’s engineers use when scoping a North American compliance program.