Look, the status of any spa and UL is a real mess. Some are listed as complete units, some only have the 'skid' of mechanicals listed, and there are at least three other variations of the UL listing out there. So, even if the spa has a UL sticker, there's a lot of uncertainty as to what it means.

The spa industry is by no means the only industry to decide that they don't need anyone telling them how to make their stuff, or that they need someone to endorse their efforst. Hard as it is to believe, not every industry is dominated by trade groups and other monopoly-fostering practices.

I'm NOT being critical or sarcastic. The fact is, even the 'unlisted' spas have a pretty damn good safety record. Yet, I expect there will be a proposal to require them to be listed- and I doubt UL will object.