Understanding regulatory requirements
Reese’s Law, enacted as a U.S. federal law in August 2022, requires manufacturers of consumer products containing button/coin cell batteries to demonstrate compliance with safety standards addressing ingestion hazards. Requirements in 16 CFR Part 1263 (the corresponding U.S. federal regulation) were published in September 2023, where UL 4200A, the Standard for Products Incorporating Button Batteries or Coin Cell Batteries was identified as the applicable safety standard. UL 4200A provides the benchmark for evaluating:
- Battery compartment design
- Mechanical performance testing
- Product markings and packaging markings
These requirements apply regardless of whether the product itself or its remote control contains button/coin cell batteries and whether the product is mains-powered or low-voltage powered. In all these cases, importers and manufacturers must demonstrate that products placed on the U.S. market comply with the requirements of the federal regulation and applicable criteria per UL 4200A, effective March 19, 2024.
Note that compliance with UL 4200A’s requirements is intended to supplement other safety standards that may apply to a specific product type and is not intended to supersede those.
UL 4200A’s application in lighting products
Lighting products with features such as dimming, color control and scene selection offer versatile functionality, where the control function can be operated via a wireless remote incorporating button/coin batteries. This accessory and similar control devices are subject to 16 CFR Part 1263 and must comply with applicable requirements of UL 4200A for:
- Access prevention: Battery compartment designs where access requires tools or two independent actions
- Durability: Resistance to crush, drop and torque forces
- Hazard communication: Permanent product/packaging warnings
- Battery retention: Secure positioning during normal use
UL Solutions UL 4200A testing and validation
We support manufacturers through:
- Compliance evaluation: UL 4200A testing and reporting
- Integrated evaluations: Concurrent assessment per applicable lighting safety standard(s) and UL 4200A
- Design review: Pre-test analysis of battery compartment security
Why UL Solutions?
As a global leader in applied safety science, we support:
- Market access: Globally recognized testing, inspection and certification services
- Risk assessment: Identification of non-compliance during product development
- Regulatory insights: Updates on evolving U.S. and international requirements
Contact our experts today to learn more about how we support lighting manufacturers and discuss your project needs.
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