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Opportunities and Impacts of Revisions to UL 2108 (Standard for Low Voltage Lighting Systems)

UL 2108

December 19, 2019

By Michael Shulman, Principal Engineer, Lighting

UL wants to help you leverage standard revisions to optimize your product offerings. In some cases, standard revisions allow you to offer new or revised products that previously were not compliant with the standard.  For other revisions, designs that were previously considered compliant may require modification and, in some cases, re-evaluation to maintain their certification.

For UL 2108, the Standard for Low Voltage Lighting Systems, revisions published on December 6th, 2019 will affect a variety of product designs.  The following is not a comprehensive list, but identifies several of the key changes.

These revisions place greater demands on product designs and will be in effect for new submittals, or revised products, as of December 6th, 2021:

  • Wet location power units that comply with UL 1310, one of the options under UL 2108 clause 17.3, will need to be marked as “double insulated”.  This is because the basic compliance criteria of UL 1310, which does not require double insulation, provides a somewhat lower threshold of protection when compared to the other methods permitted under UL 2108 clause 17.3.
  • Low voltage exposed bare conductors supplied by a class 2 power unit (clause 31.1(b)) will need an additional test, to establish comparable protection as provided by the other options listed in clause 30.1.  The test evaluates the risk of fire when a metallic object is placed across the exposed conductors, and is similar to that applied for similar designs under UL 153, the Standard for Portable Luminaires.
  • Field cuttable class 2 luminaires (typically LED flexible circuit boards) will require certain markings to be repeated at intervals so they remain present on pieces cut from a larger roll.
  • Lead wires for class 2 luminaires subject to movement after installation (such as those with adjustable lampholders) will require evaluation for secureness. This revision eliminates an exception that neglected to fully consider the fire risk associated with loose connections.
  • Luminaires with non-standard or non-replaceable lamps will require a wattage marking. This marking is provided on standardized (incandescent) lamps or as part of a lamp replacement marking on the luminaire. This new marking fills a needed information gap for alignment with the branch circuit sizing where these products are installed.
  • Installation instructions will be required for all luminaires, but without prescribing the details so very simple installs can have very simple instructions. Also, the installation instructions for class 2 luminaires with ‘unreliable’ mounting means (and tested for failure under section 65.1) will require a caution statement to avoid installing them where failure may result in personal or property damage.

These revisions expand certain allowances and opportunities, and are available to apply immediately:

  • Instructions provided with the product can be abbreviated where the full instruction set is located on a website
  • Content has been added to allow devices intended to be installed within another enclosure to be found fully compliant with UL 2108 despite having an incomplete enclosure.  Previously, such devices would only be eligible for component certification status and not eligible for field installation.

UL staff is ready to guide customers through any requested changes in certified product documentation. Our goal is to help you expand and solidify your market position by working with the most trusted partner in safety. For more information, reach out to your UL Lighting expert at

To learn more about this standard update, visit UL’s industry file review website.

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