Navigating the Regulatory Landscape of Button Cell and Coin Batteries: An Overview of Reese’s Law
Key Definition:
Reese’s Law defines “button cell or coin batteries,” as any single cell battery where the diameter exceeds its height, along with any other battery identified by the Commission as a potential ingestion risk.
In alignment with 16 CFR part 1263 requirements, the Commission has concluded that zinc-air button cell or coin batteries do not present an ingestion hazard, exempting them from the stipulations of 16 CFR part 1263. However, these batteries must still adhere to the special packaging mandates as outlined in section 3 of Reese’s Law.
Reese’s Law Section 2 – Products Containing or Designed to Use Button Cell or Coin Batteries
Under Section 2 of Reese’s Law, the CPSC is tasked with promulgating rules for button cell and coin batteries, as well as for consumer products containing such batteries. A notable outcome of this directive is the adoption of ANSI/UL 4200A-2023 as the mandatory safety standard, encapsulated in the direct final rule published at 88 FR 65274. These regulations, codified at 16 CFR part 1263, apply to relevant consumer products manufactured or imported on or after October 23, 2023, with a provision for delayed enforcement until March 19, 2024, to accommodate compliance challenges. ANSI/UL 4200A-2023 standard outlines several critical requirements:
• Battery Compartment Security: Compartment designs must necessitate tools or dual, simultaneous hand movements for access.
• Use and Abuse Testing: Battery compartments must prevent battery access or removal during testing.
• Warning Labels: Both product packaging and, where feasible, the products themselves must feature warning labels. Accompanying documentation must include these warnings as well.
Reese’s Law Section 3 – Packaging for Button Cell or Coin Batteries:
Section 3 of Reese’s Law extends the safety framework to the packaging of button cell or coin batteries, mandating compliance with 16 CFR § 1700.15 “Special Packaging” (child-resistant and senior-friendly packaging) after February 12, 2023. This provision aims to prevent accidental access and ingestion of batteries by children. An exception is made for zinc-air button cell batteries, used primarily in hearing aids, with enforcement discretion applied until March 8, 2024.
Certification and Compliance:
Manufacturers are required to certify compliance with Reese’s Law standards via a Children’s Product Certificate (CPC) for children’s products or a General Certificate of Compliance (GCC) for general-use products. This certification, as outlined in Section 14(a) of the Consumer Product Safety Act (CPSA), is crucial for affirming that products meet the requisite safety standards.
Exemptions:
CPSC has allowed for some exemptions, however they are for certain product types and for certain parts of Reese’s Law, only:
• Exemption from Reese’s Law Section 2: Toy products for children under 14 years, compliant with the battery accessibility and labeling rules of 16 CFR part 1250 (Toy Standard), are exempt from Reese’s Law section 2. Zinc-air button cell or coin batteries, deemed non-hazardous for ingestion by the Commission, are also not covered under 16 CFR part 1263 from section 2. However, they must comply with the special packaging guidelines of section 3 of Reese’s Law.
• Exemption from Reese’s Law Section 3: Batteries that meet the ANSI C18.3M Safety Standard for Portable Lithium Primary Cells and Batteries’ marking, and packaging provisions are not subject to the section 3 packaging requirements by law.
Overview and Key Dates
| Product Category | Requirement | Enforcement/Effective Date |
|---|---|---|
| Button cell or coin battery packaging | Packaging must be compliant to 16 CFR 1700.15 | Products manufactured or imported after February 12, 2023 (P.L. 117-171) |
| Zinc-air button cell or coin battery packaging | Packaging must be compliant to 16 CFR 1700.15 | Products manufactured or imported after March 8, 2024 (enforcement discretion) |
| Consumer product (for general use) containing or designed to use button cell or coin battery | Must meet performance and labeling requirements of 16 CFR part 1263 | Products manufactured or imported on or after October 23, 2023 (88 FR 65274); enforcement discretion through March 19, 2024 |
| Consumer product (for children) containing or designed to use button cell or coin battery | Must meet performance and labeling requirements of 16 CFR part 1263 | Products manufactured or imported on or after December 20, 2023 (88 FR 65274); enforcement discretion through March 19, 2024 |
| Button cell or coin battery packaging | Must meet labeling requirements of 16 CFR § 1263.4 | Products manufactured or imported after September 21, 2024 (88 FR 65296) |
Conclusion
Reese’s Law marks a crucial step forward in enhancing the safety of consumer products containing button cell and coin batteries. It introduces stringent safety, labeling, and certification standards to mitigate the risks these batteries present, particularly to children. Compliance with these regulations by manufacturers, importers, and distributors is essential for ensuring consumer safety. As the CPSC further develops and enforces these rules, industry adherence is key to maintaining a secure consumer landscape.
