In 2022, Reese’s Law was enacted to enforce safety requirements concerning coin and button cell batteries at a federal level. The primary aim of this law is to safeguard children and consumers from the potential hazards associated with ingesting these batteries. Under Reese’s Law, stringent measures have been put in place, using standards like ANSI/UL 4200A-2023, to ensure the safety of battery compartments and packaging warnings.
As of September 2023, ANSI/UL 4200A-2023 has been established as the CPSC regulatory safety standard for consumer products using button cell or coin cell batteries. Additionally, toys containing these batteries are subject to separate regulations under the latest revision of the ASTM F963-2023 Toy Standard, which outlines specific performance and labeling requirements.
Implementation: What Manufacturers Need to Know
Manufacturers of relevant children’s products are mandated to have their items tested by CPSC-accepted third-party laboratories and provide either a Children’s Product Certificate (CPC) or a General Certificate of Conformity (GCC) based on the product category. All manufacturers must self-certify their compliance with the CPSC’s new requirements. Importantly, all consumer products containing button cell or coin batteries are subject to these regulations.
Key Requirements and Standards
Construction Requirements: Battery compartments must be secured to prevent access by children, requiring either a tool or two independent hand movements to open. The accessibility of battery compartments must also be “senior-friendly.”
Performance Requirements: Products containing or designed to use these batteries must pass a series of performance tests, including crush, drop, impact, torque, and tension tests, as outlined in ANSI/UL 4200A-2023.
Labeling Requirements: Warning labels are mandatory on battery packaging, consumer product packaging, and instruction manuals. These labels must meet specific size and placement criteria outlined in ANSI/UL 4200A-2023. Additional labeling requirements include contact information for the National Battery Ingestion Hotline.
Certification: Manufacturers must obtain certification of compliance from CPSC-accepted laboratories. Children’s toy products are exempt from Reese’s Law if they comply with ASTM F963.
Compliance Timeline
Reese’s Law sets forth a timeline for compliance with its provisions:
- Button cell or coin battery packaging must meet specific requirements as of February 12, 2023.
- Zinc-air battery packaging requirements will be enforced after March 8, 2024.
- Products containing or designed to use these batteries must comply with performance and labeling requirements after March 19, 2024.
- Additional packaging requirements come into effect for products manufactured or imported after September 21, 2024.
Details and Guidelines
Detailed guidelines dictate the content, size, and placement of warning labels on packaging and products. Even products without conventional packaging must display warnings via alternative methods like hang tags or stickers.
Please feel free to contact us at inquiry@hqts.com for any inquiries related to CPSC testing or for more details.
