This article is provided by BRC Associate, UL Solutions.

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Reese’s Law represents a new future for battery safety for retailers, brands and manufacturers selling consumer products containing cell and coin batteries in the United States.

It was signed by U.S. President Biden on Aug. 16, 2022, mandating federal safety requirements for securing button cell and coin batteries, as well as the products that are powered by them, to reduce or eliminate risks of injury from ingestion by children six years of age and younger during reasonably foreseeable use or misuse conditions.

Reese’s Law went into effect on March 19, 2024, with labeling requirements for button cell and coin battery packaging taking effect after Sept. 21, 2024.

UL Solutions hardlines and battery expert Kevin Madryga replies to frequently asked questions from the retail and consumer products industry.

What products are covered under Reese’s Law, and who is affected?

Kevin: This law impacts all consumer products placed in the U.S. market with removable or nonremovable button cell or coin batteries, including consumer electronics, information technology equipment, audio and video, hard goods, accessories, apparel and footwear. The requirements affect any general-use or children’s products using such batteries, including single-cell batteries where the diameter exceeds the height or any other batteries identified by the Consumer Products Safety Commission (CPSC) as an ingestion risk.

This law affects manufacturers, importers and retailers who produce, import and/or sell covered products. 

Children’s toys are not in scope and are covered under 16 CFR 1250 (ASTM F963-23 Standard Consumer Safety Specification for Toy Safety).

What safety standard has the U.S. Consumer Product Safety Commission (CPSC) adopted for products incorporating these batteries?

Kevin: The U.S. CPSC adopted ANSI/UL 4200A-2023, the Standard for Safety for Products Incorporating Button Batteries or Coin Cell Batteries, as a safety standard for performance and labeling requirements meeting 16 CFR 1263 to establish alignment with the provisions of Reese`s Law. With a deep knowledge and understanding of 16 CFR Part 1263 and UL 4200A, UL Solutions is a trusted testing and certification company for importers and manufacturers.

Are other countries outside the U.S. pursuing similar actions?

Kevin: Many countries are reviewing the inherent dangers to child safety in button and coin cell batteries. The Australian Competition and Consumer Commission’s (ACCC) primary responsibility is to ensure that individuals and businesses comply with the commonwealth’s competition, fair trading and consumer protection laws. The ACCC developed four mandatory safety and information standards aligning with UL 4200A, Sections 5 and 6 (construction and performance), among other global industry standards, to reduce the risk of injury and death to children from exposure to button/coin batteries.

What are the packaging requirements if batteries are packaged separately and shipped with a consumer product?

Kevin: Individually packaged button/coin cell batteries (meaning they’re sold individually or packaged separately with a product using these batteries) must comply with 16 CFR 1700.15 poison prevention standards for child-resistant packaging. In addition, warning label requirements for batteries packaged separately are defined by Rule 88 FR 65296 and will enter into force for applicable products manufactured or imported after Sept. 21, 2024.

What about packaging requirements for online products delivered to consumers in a shipping carton?

Kevin: We have two possible arios in this case:

• If the online purchase product does not have its own retail packaging but is only directly contained in a shipping carton, companies should follow Subclause 7B.2 of the “Markings” requirements in Section 7 of the UL 4200A Standard for both packaging and product.
• If the retail packaging is inside the shipping carton, it must be labeled per the UL 4200A Standard. The product shall comply with all requirements when imported to the U.S. rather than after its arrival on U.S. soil.

Is it acceptable to use electronic versions of instructions for the content required by the standard?

Kevin: All warnings and safety information is required to be provided to consumers and be included physically along with the product at the point of purchase and/or delivery.

You can read more FAQs answered by UL Solutions experts by visiting the UL Solutions website here.

UL Solutions remains available at RCP@UL.com for other clarifications and technical support to help you bring compliant products to the U.S. market and other target markets for your business.