Vol. 1378 | 27 Sep 2023

Following on from the enactment of Reese’s Law in 2022, the US Consumer Product Safety Commission (CPSC) has approved 16 CFR 1263 Button Cell or Coin Batteries and Consumer Products Containing such Batteries.

This Standard establishes performance and labelling requirement for consumer products containing button cell or coin batteries to prevent child access to batteries during reasonably foreseeable use and misuse of the consumer product. Additionally, the warning requirements for packaging of button cell or coin batteries are also established.

Each consumer product containing button cell or coin batteries shall comply with ANSI/UL 4200A-2023. However, toy products that are for children under 14 years of age and comply with the battery requirements of 16 CFR 1250 is exempt from the requirements of this Standard.

ANSI/UL 4200A-2023 defines safety and design standards to limit access to batteries within battery compartments, as well as defining safety labelling requirements for products that contain button cells or coin batteries.  Some of the key requirements:


Products that contain replaceable button/coin call batteries shall require the use of a tool or coin to open the battery compartment or shall require two independent and simultaneous movements to open by hand.

If screws are used to secure the battery compartment door or cover, they shall be captive to the door or cover.

Products that include button/coin cells that are not intended for removal or replacement shall be constructed so that the cells are not accessible following a series of use and abuse tests defined in the standard.


The standard defines rules for the use of a range of warning symbols and statements, depending on the available space on the product. Some examples:

The effective date to comply with ANSI/UL 4200A-2023 is 23 October 2023. However, in recognition of limited testing availability and for the avoidance of hardship, the Commission is granting a 180-day transitional period which will end on 19 March 2024.

In addition, the packaging of button cell or coin battery shall comply with the following warning requirements:

  1. The following warning shall be present on the principal display panel, with the diameter of the icon at least 8 mm:

  2. If the space prohibits the full warning label, the icon shall be present on the principal display panel and the diameter shall be at least 20 mm. Other warning statements shall be present on the secondary display panel. Following is the example:

  3. The following safety-related statements shall be found on the principal display panel or secondary display panel:
    1. Keep in original package until ready to use.
    2. Immediately dispose of used batteries and keep away from children. Do NOT dispose of batteries in household trash.

    The safety-related statements are not applicable for button cell or coin battery packaging included separately with a consumer product.

  4. The text size of the signal word, statement of hazard and other shall be dependent on the area of the principal display panel and shall comply with the following text size requirements:

    Display area (in2) 0-2 +2-5 +5-10 +10-15 +15-30 +30-100 +100-400 +400
    Signal word (in) 3/64 1/16 3/32 7/64 1/8 5/32 1/4 1/2
    Statement of hazard (in) 3/64 3/64 1/16 3/32 3/32 7/64 5/32 1/2
    Other text (in) 1/32 3/64 1/16 1/16 5/64 3/32 7/64 5/32
  5. The height of the safety alert symbol shall be equal or exceed the height of the signal word.
  6. The effective date of the warning requirements of button cell or coin battery packaging will be effective on 21 September 2024.

If you have further questions, please contact our technical expert Carl Tso (carl.tso@intertek.com).

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