On Sept. 21, 2023, the U.S. Consumer Product Safety Commission (CPSC) published two final rules in the U.S. Federal Register.
- The Commission voted and adopted ANSI/UL 4200A-2023, as a safety Standard for Products Incorporating Button Batteries or Coin Cell Batteries, as a safety standard for performance and labeling requirements meeting 16 CFR 1263, Safety Standard for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries, to establish alignment with the provisions of Reese`s Law. This rule will be enforced on March 19, 2024.
- The Commission also included the criteria outlined in section 1263.4, addressing the labeling requirements for button cell and coin battery packaging, which will have a separate enforcement date of Sept. 21, 2024.
As a result, for products that incorporate button batteries or coin cell batteries, manufacturers and/or importers are required to provide a Children’s Product Certificate for all Children’s Products, or a General Certificate of Conformity (GCC) for General use consumer products, which are imported and sold in the U.S. market.
Note: Consumer audio video/information and communications technology (AV/ICT) equipment with button batteries or coin cell batteries are generally considered general use products (unless intended for use by children), and the GCC is a document that should be drafted by the manufacturer and/or importer, which can be supported by a Letter Report provided by UL Solutions on compliance with ANSI/UL 4200A.
- Children’s products (non-toys) that use button batteries or coin cell batteries include testing to 16 CFR 1263 and require a CPSC-accepted third-party testing provider to support CPSC submission. Toys are exempt from this rule and shall continue to comply with mandatory testing and certification.
- General use products that use button batteries or coin cell batteries include testing to 16 CFR 1263 and do not require testing by a third-party CPSC-accepted laboratory to support CPSC submission.
The impact on the audio/video, consumer electronics, and information technology industry
Audio/video (AV), consumer electronics and information technology equipment classified as general use products incorporating button batteries or coin cell batteries that are not currently designed in compliance with UL 4200A are potentially impacted. UL 4200A is not referenced in the IEC/CSA/UL 62368, the Standard for Audio/Video, Information and Communication Technology Equipment. It’s the responsibility of the manufacturer and importer to comply with U.S law regardless of the requirements in the UL Standard.
- Review the performance and labeling requirements of the 16 CFR 1263, including UL 4200A.
- Review the construction design and labeling of impacted products to determine if they fully comply with the requirements.
- Prepare the required documentation before the effective date — March 19, 2024 (and Sept. 21, 2024, for individual battery packaging).
How can UL Solutions help?
We can help you evaluate, test, and certify your devices for compliance with the UL 4200A. UL Solutions understands the impact of regulations on our customers’ business and our experts can review, and help you understand the new regulation requirements.
To stay ahead of the 2024 requirement, we suggest you start reviewing your products' current compliance.
- Final rules:
- Consumer Product Safety Improvement Act of 2008 (CPSIA)
- Commission's interpretative regulation at 16 CFR part 1200
- Children's Products | CPSC.gov
About the author
Bruna Ramos has been with UL Solutions for 12 years. She holds the position of senior product specialist and is based in São Paulo, Brazil. In this role, she focuses on providing dedicated support to the North American region’s business strategy development and implementation. Her main concentration is the consumer technology industry, specifically for services related to batteries, information technology equipment, consumer electronics products, and other related equipment on safety and performance tests and certification.