UL 4200A Battery Testing and Labeling Services for Reese’s Law

Signed by U.S. President Biden on Aug. 16, 2022, Reese’s Law mandates federal safety requirements for button cell and coin batteries. The intent of this groundbreaking rule is to eliminate or adequately reduce the risk of injury from ingestion of button cell or coin batteries by children six years of age and younger during reasonably foreseeable use or misuse conditions.

On Feb. 9, 2023, the CPSC published the Notice for Proposed Rulemaking for safety rule 16 CFR part 1263, the Safety Standard and Notification Requirements for Button Cell and Coin Batteries and Consumer Products Containing Such Batteries. This rule established performance, labeling, and other related requirements as mandated by Reese’s Law, marking a significant step forward in battery safety.

Reese’s Law and 16 CFR part 1263 have a wide scope, encompassing consumer products placed in the U.S. market with both removable and non-removable button cell or coin batteries. The requirements affect any general use or children’s product using such batteries, including single-cell batteries where the diameter exceeds the height, or any other batteries identified by CPSC as an ingestion risk, while toys and products for professional or commercial use are exempted. Product categories include, for example, consumer electronics, information technology equipment, audio and video, hard goods, accessories, apparel and footwear.

On Sept. 11, 2023, the CPSC voted unanimously to codify ANSI/UL 4200A-2023, the Standard for Safety of Products Incorporating Button Batteries or Coin Cell Batteries, as a safety standard for performance and labeling requirements of 16 CFR part 1263 Safety Standard for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries. This decision underscores the importance of UL 4200A in increasing button battery safety in accordance with Reese’s Law. The enforcement of this rule is legislated to begin on March 19, 2024.

On Sept. 21, 2023, the CPSC published a final rule to include 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.

By Mar. 19, 2024, importers and manufacturers are required to demonstrate that their products placed in the U.S. market comply with the requirements of 16 CFR part 1263. Compliance can be demonstrated through one of two certificates:

• General Certificate of Conformity (GCC) – This certificate evaluates products for compliance through testing or a reasonable testing program.
• Children’s Product Certificate (CPC) – This certificate evaluates products for compliance through testing conducted by a CPSC-accepted third-party laboratory.

By Sept. 21, 2024, importers and manufacturers are required to demonstrate or self-declare that their products placed in the U.S. market meet the requirements of section 1263.4 for labeling of button cell and coin battery packaging.

Recommendations to demonstrate compliance with Reese’s Law

Importers and manufacturers should start familiarizing themselves with the battery performance and labeling requirements of 16 CFR part 1263, including UL 4200A. They should review the construction design and labeling of their products to ensure full compliance. Manufacturers of children’s products, excluding toys, that use button cells or coin batteries should conduct testing to 16 CFR part 1263 and third-party testing for CPC submission. All required documentation should be prepared before the effective implementation dates.

UL Solutions helps with Reese’s Law compliance

UL Solutions can serve as a single-source partner to help our customers understand the certification and requirements of Reese’s Law, ultimately helping you reduce risk and position your products for success with retailers.

Importers and manufacturers should start familiarizing themselves with the battery performance and labeling requirements of 16 CFR part 1263, including UL 4200A. They should review the construction design and labeling of their products to ensure full compliance. Manufacturers of children’s products, excluding toys, that use button cells or coin batteries should conduct testing to 16 CFR part 1263 and third-party testing for CPC submission. All required documentation should be prepared before the effective implementation dates.