In February 2023, based on the Reese’s Law, the U.S. Consumer Product Safety Commission (CPSC) issued a proposed rulemaking notice to regulate the safety of consumer products containing button/coin batteries. This notice specified the scope of products, performance standards, labeling requirements, and warning messages, among other things. In September 2023, the final rulemaking document was issued, adopting UL4200A:2023 as the mandatory safety standard for consumer products containing button/coin batteries, and it was incorporated into 16 CFR part 1263. If your consumer product uses button batteries or coin batteries, this updated standard applies to you.
Enforcement date: March 19, 2024
The period from September 21, 2023, to March 19, 2024, a total of 180 days, is the enforcement transition period. The enforcement date for the 16 CFR 1263 rule is March 19, 2024.
The purpose of implementing the Reese’s Law is to protect children and other consumers from the hazards of accidental ingestion of button batteries or coin batteries. It requires the CPSC to issue a consumer product safety standard that mandates consumer products using such batteries to have child-resistant enclosures.
UL4200A aims to assess the risks associated with consumer products containing button/coin batteries, considering the potential for children to come into contact with them during normal use, leading to ingestion-related injuries.
Key updates include:
- Battery compartments containing replaceable button batteries or coin batteries must be secured, requiring the use of tools or at least two independent and simultaneous manual actions to open them.
- Battery compartments for button batteries or coin batteries must not allow such batteries to be accessible or dislodged during normal use and abuse testing.
- The packaging of the entire product must include warnings.
- If feasible, the product itself must bear warnings.
- Attached instructions and manuals must include all applicable warnings.