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Keystone can assist manufacturers n testing & certifying electronic devices.

NRTL EMC Testing

When it comes to EMC testing, a Nationally Recognized Test Lab (NRTL) like UL, TUV, SGS, ETL, etc. is not required. In short, Keystone Compliance can perform final EMC qualification testing and certification for manufacturers seeking various approvals for military, aerospace, medical, commercial, industrial, automotive, and railway/transportation applications.

It is a common misconception that final EMC qualification testing requires testing and certification from an NRTL, like UL. This is required in some cases for Electrical Safety testing. However, this is not the case for EMC testing. Keystone Compliance can assist manufacturers in testing & certifying electronic devices without the need for an NRTL.

Don’t just take our word for it, Keystone Compliance is registered with the FCC, NIST, and CE:

Keystone is also listed on the Department of Commerce’s website as an independent lab that can perform testing for CE Mark requirements for non-regulated Directives such as the EMC. As stated on the website, there is no mandatory use of a notified body under the EMC Directive.

Keystone Compliance is listed through its headquarters in Pennsylvania but its Durham, NC lab is also compliant.

Getting back to the original point about NRTLs not being required for EMC testing, here is an excerpt from the OSHA website: (

Can an NRTL use others to do part of the work necessary in testing and certifying products?

Yes, provided the NRTL has met certain criteria. OSHA has broadly grouped NRTL activities into ten “programs” and included the description and criteria for each program in Federal Register notices published on March 9, 1995 (60 FR 12980) and January 9, 2009 (74 FR 923). The first or basic program stipulates that an NRTL that will certify a product must perform all product testing and evaluation itself. An NRTL’s initial recognition will always include this first program.

The other nine programs, called “supplemental programs,” involve the NRTL’s acceptance of testing and evaluation data or services, or certain contract services, from outside parties, to perform functions necessary for the NRTLs’ testing and certification operations. An NRTL must apply for recognition to use any of the supplemental programs. OSHA will grant the request if the NRTL has met the criteria for the specific program.

Taking it one step further, here is the OSHA page that addresses Acceptance of Testing Data From Independent Organizations, Other Than NRTLS (

As was noted previously in reference to the preamble to the final rule, OSHA anticipated that most testing by an NRTL would be done in-house, but did not make this a requirement of the standard. Subcontracting out of some of the tests was anticipated by OSHA when it noted that the laboratory actually doing the work must have the necessary capability to conduct the tests, and the laboratory applying for recognition would retain primary responsibility for fulfilling the requirements of the standard and complying with the procedures set out in Appendix A.

An NRTL may accept testing conducted by an independent organization provided the following criteria are complied with:

  • The NRTL shall retain control of, and responsibility for, all aspects of the product certification scheme.
  • The NRTL shall review each test package and complete the product evaluations required by the test standards.
  • The NRTL shall ensure that all data in the test data package originated with an organization that the NRTL qualified.
  • The NRTL shall ensure that each organization providing testing data is capable of conducting the test and that the relationship between the NRTL and the organization does not compromise the NRTL’s independence.
  • The NRTL shall have a written program for assessing the qualification of the organization to perform testing for each product type it may be required to test.

This qualification program shall include procedures for evaluating the organization’s independence, facilities, utilities, environmental controls, personnel, testing and calibration equipment, written testing procedures, calibration procedures, quality assurance program, and other elements as outlined in the appropriate national consensus standards and international guides.

As an ISO-17025 accredited test lab, Keystone Compliance can provide the vast majority of pre-compliance and certification EMC testing needed by manufacturers. With Mutual Recognition Agreements through our accrediting body, Keystone Compliance’s test reports are recognized and accepted in nearly every global market.