New Mandatory Safety Standard ANSI/UL 4200A-2023 for Addressing Button Cell or Coin Battery Dangers Adopted Pursuant to Reese’s Law

September 21, 2023

On 16 August 2022, Reese's Law was enacted, empowering the CPSC to implement safety requirements for button cell and coin batteries as well as items containing them. The law was established to reduce the hazard of ingestion as swallowed batteries can cause severe injury or death.

According to the law, any item meant for consumer use that possesses or requires button cell or coin batteries is considered a "consumer product containing button cell or coin batteries." This definition holds true regardless of whether the batteries are intended to be replaced by the consumer, are pre-packaged with the product, or are sold separately. However, the law does specify that the requirements do not apply to toy products intended for children under 14 years of age if the products comply with the Toy Safety Standard, ASTM F963.

On September 11, 2023, CPSC voted to adopt the voluntary standard ANSI/UL 4200A-2023, as the mandatory safety standard for consumer products containing button cell or coin batteries. The Commission also established labelling requirements for button cell or coin battery packaging to warn consumers the ingestion danger.

Key criteria addressed by the adopted standard include:

Construction and Performance:

Products must be designed to safeguard against children gaining access to button cell or coin batteries when handling products that contain them.

ANSI/UL 4200A-2023 mandates that the battery compartment be accessible through the use of either a tool like a screwdriver or coin, or through the utilization of at least two separate and simultaneous movements. Consumer products must also undergo a series of mechanical tests that simulate plausible scenarios of both intended and unintended without releasing or exposing the batteries.

Labeling:

Reese’s Law requires warning labels that clearly specify the danger of swallowing button cell or coin batteries and advise consumers to keep both new and used batteries out of children's reach, and to immediately seek medical attention if a battery is ingested. The adopted standard provides details of required markings, warning statements and instructional information as well as a testing procedure to ensure the permanence of the markings.