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Label System Essentials for OEM Compliance

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Knowledge of Regulatory and Voluntary Standards for Product Warning Labels a Component of Risk Management for OEMs and Other Product Purveyors

The warning label depicting a hand being mangled between two sprockets may say it all, but if that cautionary note is never affixed or is not as prominently placed as the brand logo, an original equipment manufacturer (OEM) may be prohibited from globally marketing products and liable for failing to warn consumers of unreasonable risks of injury and death.

Failure to comply with labeling standards—law or industry de facto— has daunted many an OEM with lawsuits seeking damages.

In one suit, there was significant testimony about an OEM’s pneumatic nailing tool that did not bear a label warning the operator not to carry the contact-trip nailer with the trigger engaged because serious injury could result if the “trip lever is accidentally bumped against someone or something, causing it to fire.” A jury later ordered the power tool maker to pay $1.5 million in actual damages and $7.5 million in punitive damages to a carpenter who sustained head and brain injuries from a nail discharged by the tool as it was being operated by someone working nearby.

Whether it is a power tool, a major appliance, an electronic device, a hazardous substance, or industrial machinery, OEMs, retailers, and converters alike can effectively manage litigious risks and minimize the potential for consumer injuries and deaths by working with a pressure-sensitive material supplier or label converter to gain a working knowledge of appropriate voluntary and mandated regulations for warning, instructional and product identification labeling.

This white paper will explore U.S. and international product label standards, both voluntary and required; touch upon the ongoing global convergence of these principles in an effort to standardize safety label standards; and highlight the materials necessary for label compliance, aesthetics and durability.

Standard Symbiosis

The Code of Federal Regulations Part 1407—“Portable Generators: Requirements to Provide Performance and Technical Labeling” is perhaps a prime example of how U.S., industry and international standards have converged amid a global effort to standardize.

In 2007, the U.S. Consumer Product Safety Commission handed down the regulation requiring manufacturers to label portable, gas-powered generators with performance and technical data. The decision came after a commission review of generator safety revealed a spike in non-fire related carbon monoxide deaths for each of the years 1999 through 2002. The findings also noted news reports of at least 32 deaths related to portable generators during a three month period in 2006.

The roots of CFR Part 1407 stem from the American National Standards Institute (ANSI) Z535.4 Product Label Safety Standard, the recognized industry standard in the United States for product safety labeling. It represents a single cohesive guidance that covers the majority of product warnings. It has standardized formats, colors, signal words and symbols to communicate to consumers the potential of personal injury hazards.

The Z535.4 format consists of a signal-word (WARNING, CAUTION, DANGER), a message, and an optional symbol panel in either a horizontal or vertical configuration. The standard stipulates that four items need to be communicated on the label: “The nature of the hazard, the degree of hazard seriousness, the consequences involving that hazard and guidance for avoiding that hazard.”

ANSI is the United States member of the International Standards Organization (ISO), whose membership consists of 160 standards organizations from throughout the world. Where ANSI Z535.4 is the recognized standard in the United States, ISO 3864, is the international standard for warning labeling.

ISO 3864 defines four basic formats for safety through a vocabulary of shape, color and symbol. The formats are warning, prohibition, mandatory action, and safety information symbols. As seen in the labels for generators, the principles of each standard have been combined to create an effective message warning the consumer. Taken together, the principles of each can be incorporated to potentially provide OEMs with a single format for communicating warning and safety information in both U.S. and international applications.

At one time, OEMs producing products for both domestic and international markets would typically label products intended for international markets differently than those being sold solely in the US. Originally, the gap between labeling standards was vast, but globalization has resulted in a gradual convergence over the last several years to create a unified, global approach to instructional, warning and product identification labeling systems and materials. Standards organizations in the United States and Europe are continually developing a greater appreciation for each other’s safety label systems, resulting in continued alignment of ISO and ANSI standards for warning labeling. In some instances, it may be possible for a label to be in conformance with ANSI Z535.4 and ISO standards. In other situations, conformance with one standard does not mean compliance with one or more aspects of another.

UL’s Influence

Warning and nameplate labels for electrical products are tested for performance by Underwriters Laboratories (UL). In order to carry the UL mark for safety, a finished electrical device must be assembled with UL “recognized components.” Just as UL evaluates the electrical components used in a consumer product, the organization also tests label material to help ensure safe operation of the consumer device. As critical safety information is of little value to the consumer if it can’t be read, UL testing is designed to ensure that the printed image on a nameplate or warning label remains legible and that the label remains affixed to the electrical device throughout its useful life. UL 969, “Standard for Safety for Marking and Labeling Systems,” which ANSI has incorporated in its standards portfolio as ANSI/UL 969, contains the testing and performance requirements for adhesive-attached labels used as nameplates or marketing bearing information, instructions, or identification.

Before a labeling material is awarded recognized component status by UL, printed labels are evaluated for permanency, durability and legibility when applied to specific surface materials. Labels are evaluated for curling, wrinkling, shrinkage or loss of adhesion around the perimeter, when applied to specified surfaces.

UL 969 testing includes legibility, defacement, adhesion, and appropriate environmental conditioning, including exposure to specified agents. According to UL, this includes testing for sunlight resistance (UV performance), exposure to extreme temperatures and high humidity; or exposure to certain oils, detergents or petroleum products. The testing examines complete marking and labeling systems, including the materials, overlaminates, adhesives and printing inks. Depending on the type of testing performed, UL evaluations can frequently take several weeks to complete.

In order to shorten the time required to achieve UL recognition, base materials providers and converters will submit material to UL for preapproval. In this process, UL conducts its evaluation of the label materials and printing inks submitted in advance of a specific need. Materials and ink systems meeting the specified performance requirements are granted recognized component status. These successful submissions are then added to the converter’s or base material supplier’s UL file. An OEM, in concert with its converter, can then choose from these preapproved materials for its labeling needs, avoiding the time and expense of testing. OEMs should consult with their label provider in order to choose the appropriate material for a new application.

European Directives

Products sold into the countries of the European Union are required to display the “CE” mark, indicating conformance with the legal requirements of applicable EU directives. The CE mark, meaning “Confirmite Europeene” or European Conformity indicates that a product complies with the essential requirements of the applicable European laws or directives with respect to safety, health, environment, and consumer protection. Unlike the UL mark, the CE designation is not an indication of quality or successful testing; rather, it simply indicates legal conformity to the various EU directives, so that the product carrying the mark can be traded freely between EU countries.

There are more than 30 directives from the EU that require that products display the CE mark. Unfortunately, there is no comprehensive list of the products that require the mark. Therefore, it is the manufacturer’s responsibility to determine if a product requires a CE marking.

The “crossed out wheelie bin” is the symbol representing the EU’s Waste Electrical and Electronic Equipment Directive (WEEE) which, together with the Reduction of Hazardous Substance Directive (RoHS), became European Law in 2003, setting collection, recycling and recovery targets for all types of electrical goods. The WEEE directive imposes the responsibility for the disposal of waste electrical and electronic equipment on the manufacturers of such equipment. The legislation also provides for the creation of collection schemes where consumers return their used e-waste free of charge. The objective is to increase the recycling and/or re-use of such products. It also requires heavy metals such as lead, mercury, cadmium, and chromium and flame retardants such as polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE) to be substituted with safer, more environmentally-friendly alternatives.


The number and variety of products requiring instructional, warning or product identification labels will continue to increase. Product safety label standards developed in the United States and internationally will continue to evolve and converge toward global standardization. In order to achieve compliance while maintaining speed-to-market, design engineers rely on knowledgeable label material suppliers to understand these evolving requirements and provide the proper materials and printing systems for each product.

That’s why OEMs and converters benefit from partnering with a labeling system provider that can help them understand and navigate the regulatory compliance landscape, for in a global economy, using symbols to communicate safety information is as practical as it is essential.


  1. Avoiding Product Liability Lawsuits, CED Magazine, August 2006
  2. http://www.ul.com
  3. http://www.iso.org
  4. http://www.ansi.org
  5. www.export.gov