The United States recently published two final decisions in the Federal Register

1、Volume 88, Page 65274 – Direct Final Decision

Effective date: come into force from October 23, 2023. Taking into account testing availability, the Commission will grant a 180 days enforcement transition period from September 21, 2023 to March 19, 2024.

Final rule: incorporate UL 4200A-2023 into federal regulations as a mandatory consumer product safety rule for consumer products containing coin cells or coin batteries.

2、Volume 88 Page 65296 – Final Decision

Effective date: come into force from September 21, 2024.

Final rule: the labeling requirements for button cell or coin battery packaging needs to meet the requirements of 16 CFR Part 1263. Since UL 4200A-2023 does not involve labeling of battery packaging, the labeling is required on button cell or coin battery packaging.

The source of both decisions is because the U.S. Consumer Product Safety Commission (CPSC) has approved a mandatory standard in the recent vote– ANSI/UL 4200A-2023, mandatory safety rules for consumer products containing button cells or button batteries.

Earlier in February 2023, in accordance with the requirements of “Reese’s Law” promulgated on August 16, 2022, the CPSC issued a Notice of Proposed Rulemaking (NPR) to regulate the safety of consumer products that containing button cells or button batteries (referring to MCM 34^th Journal).

UL 4200A-2023 analysis

Product Scope

1.Consumer products containing button cells/batteries or coin cells/batteries. For example, luminous children’s clothing/shoes (using button batteries as power source), such as remote control.

2.Exemption of “toy products” (Any toy designed, manufactured or sold for children under 14 years of age). The reason is that toy products are controlled by Federal Regulations 16 CFR 1250 and need to meet ASTM F963 standards. However, children’s products containing coin cells or coin batteries that are not “toy products” will need to meet the performance and labeling requirements in the final rule.

UL 4200A-2023 performance requirements

Performance requirements for consumer products with replaceable button batteries or button batteries

Products containing button batteries or coin batteries, which are not suitable for user disassembly or replacement, should effectively prevent users or children from disassembling the battery.

Label requirements of UL 4200A-2023

• Colored markings must comply with the ISO 3864 standards series;
• Color is required only when the markings are printed on a label using more than one color;
• Manufacturers may choose to use either the “Keep out of Reach of Children” icon or the “Warning: Contains Coin Battery” icon on the consumer product packaging label;
• Permanence of markings is tested consistent with the requirements in Ul62368-1, section F.3.9;
• Include an additional warning statement in instructions and manuals to “Always completely secure the battery compartment”. If the battery compartment does not close securely, stop using the product, remove the batteries, and keep it away from children.

Battery packaging/product packaging requirements

Recommended warning label requirements on battery packaging

Recommended warning label requirements on product packaging

Recommended warning label requirements on the product body

Additional warnings on battery packaging and consumer product manuals/manuals

1. “Dispose of used batteries immediately and keep them away from children. Do not dispose of batteries in household garbage.”

2. “Even used batteries can cause serious injury or even death.”

3. “Call your local poison control center for treatment information.”

To sum up

In response to the Reese‘s Law, these two decisions published in the Federal Register are for the performance requirements of the battery compartment of the button cell or coin battery and the products containing such batteries, and do not include the performance requirements of the button battery itself. The safety performance requirements for the battery compartment must meet UL 4200A-2023, and the battery packaging and product packaging must meet 16 CFR Part 1263.