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

UL Solutions can help manufacturers understand the requirements of Reese’s Law, demonstrate compliance, reduce risk and position their products for success with retailers.

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Navigate button battery safety standard with confidence

With the Consumer Product Safety Commission (CPSC) codifying UL 4200A, the Standard for Products Incorporating Button Batteries or Coin Cell Batteries, as a safety standard for battery compartment accessibility and labeling requirements of 16 CFR (Code of Federal Regulations) part 1263 to support Reese’s Law, UL Solutions can help manufacturers and retailers understand the requirements of Reese’s Law, demonstrate compliance, reduce risk and position their products for success.

Overview of Reese’s Law and 16 CFR part 1263

Reese’s Law: A new era in battery safety

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.

16 CFR part 1263: Implementing Reese’s Law

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.

Infographic showing consumer products with both removable and non-removable button cell or coin batteries

UL 4200A codified as a battery safety standard

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.

Requirements within UL 4200A include:

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Construction testing to validate that the design minimizes the risk of children removing and ingesting/aspirating the batteries.

This includes the two following product design scenarios:

  • Replaceable battery designs for battery accessibility and battery compartment security
  • Non-replaceable battery designs for battery inaccessibility and battery security
Icon of a battery with a warning symbol

Performance testing:

  • Pre-conditioning – stress relief and battery replacement tests as applicable
  • Abuse – drop (portable and hand-held products), impact, crush, torque, tension, and compression tests
  • Secureness – applicable to accessible button/coin cell batteries that are not intended for user removal and replacement
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Markings on packaging and product, including permanence of such markings

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Instructions delineating requirements for replaceable and non-replaceable button cell and coin batteries

Section 1263.4 labeling requirements for battery packaging

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.

Implementation timeline

Reese's Law Timeline

Compliance with 16 CFR part 1263 and UL 4200A

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.

Compliance with Section 1263.4

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.

Leverage UL Solutions’ battery safety expertise

With deep knowledge and understanding of the requirements of 16 CFR part 1263 and UL 4200A, UL Solutions is a trusted partner for importers and manufacturers. We have over a century of expertise in compliance and safety testing. Our technical experts, who cover more than 150 countries, sit on international committees that develop industry standards and updates.

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Leverage UL Solutions’ retail industry expertise

UL Solutions offers holistic capabilities, unique services and a broad range of offerings throughout the product lifecycle to meet the needs of multiple retailers’ specifications. By leveraging our strategic and integrated partnerships with the world’s largest retailers, you can gain efficiency and competitive advantage.

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Leverage UL Solutions’ leadership in safety science

We work with you to navigate the complexities of the global marketplace, from compliance issues to trade challenges. Our breadth of safety science infrastructure and front-line knowledge of regulatory and compliance requirements help you reduce noncompliance risks, solve supply chain problems, and better manage your overall cost of quality. With our help, you’re equipped to navigate the regulatory landscape and succeed in today’s competitive market.

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