Listed, Labeled and Approved: Three Words That Are Not the Same
Why this matters
Three words carry most of the weight when an inspector decides whether a product may stay on the job, and the trade uses them as if they meant the same thing. They do not. A product can be on a testing lab's list and carry no mark, carry a mark and be on no list, or carry both and still be refused. A tech who hears "it's listed" and stops thinking walks into a failed inspection on a product that was genuinely certified, or defends a product that only looked certified. This card owns the vocabulary for the rest of the codes group, so the definitions are worked out here once and the siblings point back.
Where the definitions live
The words are defined terms, which means the code gives them a meaning narrower than ordinary speech and every section that uses them inherits that meaning.
- NEC Article 100 defines listed, labeled, approved and identified for electrical work, as adopted by your jurisdiction.
- The I-codes' Chapter 2 (IRC R202, IMC and IFGC Section 202, IPC Section 202, IBC Section 202) defines listed, labeled, approved and approved agency for building, mechanical, gas and plumbing work, again only where your state or city has adopted that code.
The wording differs a little between the two families and the substance is the same. Paraphrased:
Listed means the product appears in a list published by an organization that the authority having jurisdiction (AHJ, the official or office that enforces the code on your job) finds acceptable, that is concerned with evaluating products, that keeps up periodic inspection of production, and whose listing says the product meets named standards or was tested and found suitable for a specified purpose.
Labeled means the product carries the label, symbol or other identifying mark of such an organization, showing compliance with standards or performance in a specified way. The I-code version adds that the organization maintains periodic inspection of production of the labeled items.
Approved means acceptable to the AHJ. In the I-codes, acceptable to the building official or code official. That is the whole definition.
Two companion words come up often enough to belong here. Identified, in NEC Article 100, means recognizable as suitable for a specific purpose, function, use or environment, and the NEC notes that listing or labeling is one way to establish it. Approved agency, in the I-codes, is an established testing or inspection agency the official has accepted, which is how a lumber grading bureau or a special inspection firm gets its authority on a job.
The three answer three different questions
Read the definitions as questions and they stop blurring.
| Word | The question it answers | Who answers it | Where the evidence sits |
|---|---|---|---|
| Listed | Did a qualified organization evaluate this product, for what, and is production still being watched? | The testing organization | Its published directory |
| Labeled | Can I tell, standing in front of it, that this item came from that production? | The testing organization, through the mark it authorizes | The item, or sometimes its smallest package |
| Approved | Will this official accept this item on this job? | The AHJ, and only the AHJ | The inspection result, a written decision, or the code text the official enforces |
Listing is a fact about a population of products in a directory. Labeling is a fact about one physical item. Approval is a decision about one installation. Because three different parties answer the three questions, nothing forces the answers to agree.
Every combination exists in the field
This is the part that is worth carrying in your head, because each combination has a different first move.
Listed, labeled, approved. The normal case. The NEC still reads the listing as limited to what was listed: listed equipment is installed and used per its listing and instructions. See related: The Installation Instructions Are Part of the Code.
Listed but not labeled. The product is genuinely in the directory and the item in your hand carries no visible mark. Common causes: the label was painted over, peeled off in a hot attic, or was on a part that got replaced; or the listing allows the mark on the smallest shipping container rather than the item, which is how some small fittings and connectors are handled. First move: find the carton, the instruction sheet or the directory record, because the inspector cannot see a listing that is not on the item.
Labeled but not listed. The item carries a mark and there is no current listing behind it. This is the dangerous one. Causes: a counterfeit mark; a listing that was withdrawn or expired while old stock kept circulating; a mark from a lab that is not recognized for that product's standard (see related: What a Nationally Recognized Testing Laboratory Is); or a mark that is not a listing at all, such as a European conformity mark, which is a manufacturer's self-declaration under European law and not a US listing. First move: look the mark up rather than trusting it.
Listed and labeled, not approved. The product is real and certified and the official refuses it on this job. Causes: it is listed for a different use than yours; a local amendment prohibits it (Chicago, for example, has long restricted nonmetallic sheathed cable that most of the country accepts as listed building wire); or the installation departs from the listing. First move: ask the official which of those it is, because the remedy is completely different for each.
Approved but not listed. The official accepts something that carries no listing at all. This is legitimate in three ways: the code section does not require listing for that product (dimensional lumber needs a grade stamp from an approved agency, not a listing); the official accepts it as an alternative under the code's alternative materials and methods section (IRC R104.11 in the 2021 edition, renumbered in later editions); or the item was field evaluated and field labeled. See related: Field Evaluation When a Product Has No Listing.
None of the three. Obvious on paper, less obvious in an old house, where a lot of equipment predates the listing requirement that would apply to it today.
Why the code needs all three words
It would be simpler if listing were approval. The codes refuse that on purpose. The testing organization knows the product and has never seen your job. The official knows your job and has never torn down the product. Listing hands the official a reliable shortcut, and the NEC states the shortcut directly: under NEC 90.7, as adopted, the inspector is not expected to re-examine the internal construction of listed equipment, because the lab already did. The official keeps the final word because only the official sees the installation: the location, the clearances, the combination of products and the local amendments.
That is also why "approved" never transfers. An approval on a neighbor's job, on a previous permit or in another county is evidence of how an official reasoned once. It is not approval here.
Worked example: one rough-in, four items, four different states
A small shop is finishing a basement: a new subpanel feeder, a bath exhaust fan, a run of flexible gas line to a dryer, and an imported wall heater the homeowner bought online. The rough-in inspection is in two days, and the office runs the four items through the three questions.
Item 1, feeder cable. The jacket carries a mark, the reel label names the listing category, and the jurisdiction has adopted the NEC without restricting the cable type. Listed: yes, confirmed in the directory by the file number printed on the jacket. Labeled: yes, on the jacket at intervals. Approved: expected, because nothing in the local amendments touches it. Status: normal. Time spent: about 5 minutes.
Item 2, exhaust fan. The fan is listed for use over a tub or shower only when it is on a GFCI-protected branch circuit, a condition printed in its instructions, and the plan has it on a plain lighting circuit. Listed: yes. Labeled: yes. Approved: no, not as planned, because the installation would sit outside the listing's own condition. The fix is a protection change on the circuit, decided before the drywall goes up. Time spent: about 15 minutes, plus a line on the material list. Note what the fix is not: it is not a different fan, because nothing is wrong with the fan.
Item 3, gas line. The flexible line carries the manufacturer's marking and the carton says listed, and the jurisdiction's adopted fuel gas code plus the manufacturer's instructions require a bonding conductor that the plan did not include. Listed and labeled: yes. Approved: only with the bond, so the bond goes on the plan. This is the same shape as item 2, a real listing with a condition attached.
Item 4, imported heater. The heater carries a European conformity mark and a plug designed for another country, and the online listing called it "certified." Directory search on the lab identifiers it carries: no US listing found. Listed: no. Labeled: yes, in the sense that it carries a mark, and no, in the sense the code means, because the mark is not from an organization acceptable to the AHJ for a US listing. Approved: not as it stands. The paths are a listed replacement, or a field evaluation that the official agrees in advance to accept. The office calls the homeowner that afternoon rather than letting the tech discover it at the wall with a drill in hand.
Tally the result honestly: one item was in the normal state, two were listed and labeled and still needed a change to be approvable, and one had a mark and no listing. Three of the four items carried a genuine listing, and only one of those three was ready as planned. The marks on all four told the office almost nothing until each was read against the three questions.
What changes the answer
The adopted code, not the newest one. If your jurisdiction is on an older edition, the definitions above are the same in substance, and the section that requires listing for a given product may differ. See related: Building Code Cycles + State Adoption.
Workplace versus dwelling. In a workplace, OSHA requires electrical equipment to be approved under 29 CFR 1910.303(a), and its definitions at 29 CFR 1910.399 tie "acceptable" to certification by a nationally recognized testing laboratory. That duty runs to the employer and covers the employer's workplace, so it binds the shop's own building and a commercial customer's floor; it does not govern a homeowner's basement, where the adopted code is what applies.
A jurisdiction that keeps its own list. A few states and cities have historically decided for themselves which testing organizations they accept rather than taking any recognized lab, which turns "listed" from a national fact into a local one. If yours does, the directory search is not finished until you check their list too.
How to verify you got the vocabulary right on a job
For each product the inspector will see, write three words next to it: listed (where you confirmed it), labeled (where the mark is on the item), approved (what the official said or what code text you are relying on). If any line has a blank, that is the item to resolve before the inspection, not during it. And if you catch yourself writing "listed" as the answer to the approval question, that is the exact collapse this card exists to prevent.
References
- NFPA 70 (National Electrical Code), Article 100 definitions and 90.7, in the edition your jurisdiction has adopted
- International Residential Code R202 and the matching Section 202 definitions in the IMC, IFGC, IPC and IBC, as adopted; IRC R104.11 (2021 edition) on alternative materials and methods
- 29 CFR 1910.303(a) and 1910.399, for workplace electrical equipment approval
- See related: What a Listing Mark Means and What It Does Not; Working With the Authority Having Jurisdiction: The Basics; Building Codes Hierarchy Reference