In accordance with the requirements of the Reese Act, the U.S. Consumer Product Safety Commission (CPSC) has established ANSI/UL 4200A-2023 as mandatory consumer product safety rules for consumer products containing button batteries or button batteries in order to eliminate or reduce the risk of injury to children six years old and younger due to ingestion of button/coin batteries, and has incorporated 16 CFR 1263 to regulate the consumer product safety of such products.

The regulation, which will be enforced on March 19, 2024, applies to consumer products containing button batteries or coin batteries, and excludes toy products intended for use by children under the age of 14 (toy products must comply with the requirements of 16 CFR 1250 and zinc-air batteries).

ANSI/UL 4200A-2023 systematically requires button battery-containing products from various aspects such as structure, testing, warning labels (product body and packaging), and instructions.

 Product structure:

1. For terminal products with “batteries that allow users to move or replace”, the structure needs to meet the following requirements:

a. IEC 61032 test probe No. 11 must not come into contact with the battery. Enclosures that can be opened without the aid of tools, or enclosures that can be opened by hand with less than two independent consecutive movements, are to be opened for evaluation during inspection.

b. Products need to be designed to prevent children from moving the battery:

A tool (such as a screwdriver, coin) is required to open the battery chamber. A minimum rotation angle of at least 0.5Nm and 90 degrees is required to open the battery chamber, or the fastener should engage at least two complete threads; or by hand, at least two independent and simultaneous actions are required to open the lid or door of the battery chamber.

c. If the cover or door of the battery compartment is fixed by screws or similar fasteners, the fasteners must be restricted to the cover or door, such as not loosening the screws.

2. When a product has a “battery that cannot be moved or replaced by the user”, it is necessary to effectively prevent removal by the user or children. The product should be designed to:

a. Make the battery inaccessible through a housing or similar means;

b. Or completely secure the battery by welding, riveting or similar means.

Test requirements:

Structural requirements;

pretreatment requirements;

Abuse testing (drop test, impact test, crush test, torque test, tensile test, stress test, compliance test);

Safety testing;

Product and packaging identification requirements;

Instructions requirements.

Warning label:

Requirements for the main display surface of product packaging:

Requirements for product ontology display:

LCS Reminder:

Manufacturers of products powered by button batteries (excluding toys already covered in the ASTM F963 Toy Safety Standard) should comply with a range of new regulations, performance, labeling and certification requirements to ensure smooth market launches.