Imagine this scenario. A contractor sources butterfly valves for a Toronto high-rise from an American supplier. The valve label says “UL Listed, FM Approved” — two credible approval marks that would be accepted on many US projects. The submittal goes in for review and comes back rejected. The reason: nothing on the valve or in the documentation shows certification to Canadian requirements — no cULus, cUL or ULC mark.
That rejection feels arbitrary until you understand the structure of fire protection approvals in North America. UL, FM, and ULC are three different certification marks with three different roles, and Canada treats them differently than the US does. Assuming “UL Listed” is always good enough is one of the easiest ways to get a fire protection submittal rejected on a Canadian project.
This article explains what each approval means, when it applies, and how to specify listings correctly for a Canadian project. It’s written for contractors, mechanical and fire protection engineers, spec writers, and anyone preparing a fire protection submittal that has to survive an AHJ review north of the border.
Meet the Three Organizations
Start by understanding what UL, FM, and ULC actually are. They’re often lumped together, but they have distinct histories, geographies, and purposes.
Underwriters Laboratories (UL)
Founded in 1894 with backing from fire insurance underwriters, Underwriters Laboratories began as an electrical testing laboratory. Since a 2022 restructuring, the work is split between separate organizations: UL Solutions, headquartered in Northbrook, Illinois, tests and certifies products, while the non-profit UL Standards & Engagement (ULSE) develops the standards.
In fire protection, commonly referenced standards include UL 1091 for butterfly valves, UL 262 for gate valves, UL 199 for sprinklers, and UL 448 for centrifugal fire pumps. All except UL 262 are now joint Canada–US standards (ANSI/CAN/UL/ULC 1091, ANSI/CAN/UL/ULC 199 and ANSI/CAN/UL 448). A product that passes evaluation and stays under UL’s follow-up inspection program earns the right to carry the UL Listing Mark.
A UL Mark without a Canadian indicator is a US certification. It does not automatically confer Canadian acceptance.
FM Approvals (FM, formerly FM Global)
FM Approvals is the product certification arm of FM (branded FM Global until 2024), a commercial property insurer headquartered in Johnston, Rhode Island. FM Approvals certifies products against its own examination standards, written with property loss prevention in mind.
Those standards carry FM class numbers — for example FM 1112 for indicating butterfly and ball valves, FM 1120/1130 for OS&Y and NRS gate valves, FM 1210 for swing check valves, and FM 1311 for horizontal split-case fire pumps. They are separate from FM’s Property Loss Prevention Data Sheets, which are design and installation guidelines.
A standard FM APPROVED mark is not a substitute for a Canadian listing; on Canadian projects it is usually an additional credential. FM’s data sheets generally call for FM Approved equipment where it is applicable and available, so owners insured by FM typically ask for FM Approved components on top of the base listing.
Underwriters Laboratories of Canada (ULC)
ULC was founded in 1920 and is based in Toronto. Today it operates under the UL Solutions brand as an SCC-accredited certification body with its own ULC Mark, while the CAN/ULC standards are published by UL Standards & Engagement.
CAN/ULC standards are National Standards of Canada. Some are Canada-only, such as CAN/ULC-S520 for fire hydrants and CAN/ULC-S548 for waterflow and supervisory switches, while many fire protection product standards are now joint Canada–US documents, such as ANSI/CAN/UL/ULC 312 for check valves. Where no national standard exists, ULC certifies to an Other Recognized Document — gate valves, for example, to ULC/ORD-C262.
A ULC Listed product has been evaluated by ULC to the applicable Canadian requirements and is covered by periodic factory follow-up visits. That detail matters, and it’s the key to understanding what Canada accepts.
The Cardinal Rule: What Canada Actually Accepts
Canadian codes don’t name a certification brand; they rely on accredited certification. The Ontario Fire Code defines “listed” equipment as equipment or materials that appear in a list published by a certification organization accredited by the Standards Council of Canada (SCC). The Ontario Building Code generally requires sprinkler systems to conform to NFPA 13, which requires the materials and devices essential to the system’s operation to be listed.
In practice, Canadian reviewers typically look for certification to Canadian requirements by an SCC-accredited certification body, shown by a Canadian certification mark on the product and confirmed in the certification directory. Everything else follows from that.
Several certification bodies hold SCC accreditation, each with a published scope, so check that the scope covers the product in question. Examples relevant to fire protection include:
- UL Solutions (the ULC Mark, and the UL Mark with a “C” or a “C” and “US”)
- Intertek (the ETL Listed Mark with the “C” identifier)
- CSA Group (where the specific product category is within its accreditation scope)
- FM Approvals (the FM APPROVED mark with a “C”, for products approved in accordance with Canadian codes and standards)
A US-only UL Listing doesn’t meet that expectation. UL Solutions is itself SCC-accredited, but a UL Mark without a Canadian indicator shows certification to US requirements only. That’s why a “UL Listed” American butterfly valve can be rejected in Toronto while an apparently similar “cULus Listed” valve passes. The difference isn’t necessarily in the physical product; it’s in which requirements the product was certified to.
The cULus Shortcut
UL Solutions can certify a product to both US and Canadian requirements and show both on a single mark: the UL symbol with a “C” and a “US” beside it, usually written cULus. The “C” indicates compliance with the applicable Canadian standard and the “US” with the US standard. On UL’s newer Enhanced Mark, the same information appears as “CA” and “US” country codes.
A cULus Listed product is recognized in both countries, and because many fire protection product standards are now joint Canada–US documents, one standard can cover both markets. For Canadian projects, “cULus or ULC Listed” is a straightforward, defensible listing to specify.
How to Write a Canadian Spec Line That Won’t Get Rejected
Getting the listing right on paper prevents the rejection on site. Four disciplines make Canadian specifications defensible.
Name the listing explicitly. Don’t write “UL Listed.” Write “cULus or ULC Listed to ANSI/CAN/UL/ULC 1091, 175 psi minimum working pressure.” The second version tells the plan reviewer exactly which standard and which program applies.
Require the listing card in the submittal package. A data sheet from the manufacturer is not proof of listing. The listing card — the certification body’s directory entry tying a specific model number to a specific standard — is the defensible reference. Require a copy to appear in the submittal package.
Specify FM Approval separately when it’s required. FM Approval is not implied by UL or cULus. If the project is insured by FM or the owner has a policy requiring FM Approved fire protection, add “and FM Approved” as a separate line. Don’t assume it’s bundled.
Don’t accept “equivalent to” substitutions on listings. A contractor substitution request that says “equivalent to cULus Listed” is not acceptable. Either the substitute product carries a listing to the applicable Canadian requirements from an SCC-accredited certification body, or it doesn’t. There’s no gray zone.
A Quick Reference: Common Products and Typical Listings
The following table shows typical Canadian listings for common fire protection products and the standard each is usually based on. It assumes a project under a provincial building code and fire code (in Ontario, the Ontario Building Code and the Ontario Fire Code). Always confirm the exact listing basis in the certification directory.
| Product | Typical Canadian Listing | Typical Add-On |
|---|---|---|
| Butterfly valve (indicating) | cULus or ULC Listed, ANSI/CAN/UL/ULC 1091 | FM 1112 if insurer requires |
| OS&Y gate valve | cULus or ULC Listed, ULC/ORD-C262 (UL 262 in the US) | FM 1120 if insurer requires |
| Swing check valve | cULus or ULC Listed, ANSI/CAN/UL/ULC 312 | FM 1210 if insurer requires |
| Fire pump (horizontal split-case) | cULus or ULC Listed, ANSI/CAN/UL 448 | FM 1311 if insurer requires |
| Sprinkler head | cULus or ULC Listed, ANSI/CAN/UL/ULC 199 | FM 2000 if insurer requires |
| Fire Department Connection (FDC) | cULus or ULC Listed, ANSI/CAN/UL 405 | FM 1530 if insurer requires |
| Grooved coupling | cULus or ULC Listed, ANSI/CAN/UL 213 | FM 1920 if insurer requires |
The pattern is consistent. A Canadian listing is the baseline. FM Approval is an additional credential layered on top when the insurance carrier requires it. ULC-only listings exist for some Canadian-specific product categories, while cULus listings are common on products sold in both countries.
Ontario Building Code and Toronto Practice
Since January 1, 2025, the Ontario Building Code has consisted of the National Building Code of Canada 2020 with Ontario amendments. It requires sprinkler systems, standpipe systems and fire pumps to conform to NFPA 13, NFPA 14 and NFPA 20 respectively, so much of the underlying design basis matches US practice. The differences tend to appear in the listing requirements and the submittal documentation — exactly where this article has been focused.
In Toronto, sprinkler and fire alarm work goes through a building permit with the City’s building division (Toronto Building), which reviews it under the OBC, while Toronto Fire Services inspects buildings and enforces the Ontario Fire Code. Standardizing on cULus Listed products can also simplify stock management: the same part number serves US and Canadian projects.
For a broader reference on fire protection supply across Toronto and the GTA, see our fire protection supplier in Toronto page.
Common Misunderstandings
A few recurring misunderstandings come up in submittal reviews.
“FM Approved is the highest level, so it should cover everything.” No. FM Approved is a different program, not a superset. A standard FM APPROVED mark shows compliance with FM’s own standards, not with Canadian requirements, so on its own it is not a Canadian listing. FM and UL/ULC test for overlapping but distinct things.
“ULC is just Canada’s version of UL — they’re identical.” Not quite. ULC is part of UL Solutions and many fire protection standards are joint Canada–US documents, but Canadian requirements can still differ, and some products are certified to Canadian requirements only. A cULus mark shows certification to both, which is why it’s convenient.
“We can grandfather the existing UL-only valves on a retrofit.” Codes are generally not applied retroactively, so the existing installation can usually stay in service unless local regulations say otherwise. But a replacement or new addition is expected to meet current requirements, so the replacement valve should carry a Canadian listing, even if the valve next to it was installed 20 years ago under an older code.
“The manufacturer’s catalog shows the UL logo — that’s enough.” The catalog shows what the manufacturer claims. The certification body’s directory shows what it has actually certified, and to which standard. Always require the listing card.
Frequently Asked Questions
Is a UL Listed valve acceptable in a Canadian project? Generally not, if the listing is US-only. Canadian reviewers typically expect certification to Canadian requirements by an SCC-accredited certification body. Use a cULus Listed or ULC Listed product instead.
Is FM Approval enough on its own? Usually not. A standard FM Approval addresses loss prevention performance against FM’s own standards and does not substitute for a Canadian listing, so Canadian projects normally still need a cULus or ULC Listing as well. FM does offer a “C” version of its mark for products approved to Canadian codes and standards; if you plan to rely on it, confirm acceptance with the engineer and the AHJ first.
What does the cULus mark mean? It means UL Solutions has certified the product to both US and Canadian requirements. The “C” indicates compliance with the applicable Canadian standard and the “US” with the US standard. It’s recognized in both countries.
Are Intertek ETL and CSA listings acceptable in Canada? They can be. Intertek and CSA Group are both SCC-accredited certification bodies, so a listing to the applicable Canadian standard can qualify where the product category falls within their accreditation scope and the AHJ accepts it. For Intertek, look for the ETL Listed Mark with the “C” identifier.
Do I have to replace UL-only valves on a retrofit project? Generally no; codes are not normally applied retroactively to an existing installation unless local regulations require it. However, any valve added or replaced as part of the retrofit is expected to meet current requirements — meaning new components should carry a Canadian listing such as cULus or ULC. Confirm with the AHJ.
Where do I find a product’s listing card? The listing card is the product’s entry in the certification body’s online directory. UL, cUL and ULC listings are all in UL Product iQ, UL Solutions’ certification directory (registration is free). FM Approved products are in FM Approvals’ online Approval Guide. Request a copy from the manufacturer as part of the submittal package.
Next Steps
Three takeaways summarize the entire Canadian approval landscape. First, a Canadian listing — cULus, ULC or an equivalent Canadian mark from another SCC-accredited certification body — is the baseline for fire protection products in Canadian projects; a US-only UL Listing is not enough. Second, specify the listing explicitly in the project documents, including the standard number and the requirement to provide the listing card. Third, treat FM Approval as an additional credential for insurance purposes, not a replacement for the Canadian listing.
If you’re sourcing cULus Listed fire protection products — butterfly valves, OS&Y gate valves, fire pumps, sprinkler components, grooved fittings — for a Toronto or Canadian project, explore the ValveAtlas fire protection catalog or contact our technical team for submittal-ready listing documentation. We supply products with the correct Canadian listings to help your submittal package go through on the first pass.
