Recently, Underwriters Laboratories sent a letter to NEMA Luminaire manufacturers announcing a January 1, 2009 requirement to implement holographic labeling in support of an expanding UL program to fight counterfeit products.  Historically, UL has only applied these requirements to products made overseas, China notably.
NEMA manufacturers are naturally concerned about counterfeiting, but are pushing back against the new UL label for more time and if possible more flexibility in the application and implementation of the label.  At issue is the reality of changing dozens if not hundreds of manufacturing lines and designing, acquiring (from a sole-source UL printer no less) and implementing the new labels.  Currently, there appears to be no provision for combination labeling involving user-made additions to the labels, and obviously no local printing.
Most manufacturers implement local, licensed printing of combination labels to save cost, time and space on the devices.  For manufacturers who use mechanical marking, such as casting or additions to the product dies, a new label will have to be physically applied.  Manufacturers currently implement physical and paper labels, as best fit their product and management decisions.  Product lines are obviously tooled to these parameters.  Any changes to this practice will have to be at individual cost by each manufacturer, not including the cost and time of acquiring the labels to begin with.  At least one NEMA manufacturer just recently upgraded their product lines for local printing, and their investment is at risk of being totally negated.
The Luminaire Section of NEMA has drafted a letter to UL management to be delivered shortly.  The intent of the letter is to voice NEMA concerns and predicted impacts, pointing out its concerns and making a request for technical discussions and asking for more time to implement the new requirement.  While new labeling might be inevitable, more time to implement it will lessen the immediate impacts of cost and time. Manufacturers and NEMA Product Section managers are encouraged to interact with their UL counterparts to ascertain existing and potential UL initiatives regarding new labeling for their product sections.  It is worth pointing out that the Luminaire Section UL technical contacts had not heard of the new Holographic labeling requirement until asked by the manufacturers about it. 
Product managers and manufacturers: don't wait for your UL liaisons to call you, call them first.

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