Background

The Consumer Product Safety Commission has issued a final rule establishing a mandatory safety standard for button cell or coin batteries that includes requirements for consumer goods using such batteries. The CPSC has also issued a separate final rule that requires warning labels on the packaging of such batteries.

Button cell or coin batteries are generally small, single-cell batteries that range from 5 mm to 32 mm in diameter and 1 mm to 6 mm in thickness, but they come in many shapes and sizes and are composed of different materials and chemicals. Consumer products that use such batteries (and are within the scope of this rule) include common household portable devices, wearable accessories, and decorative electronic devices. Examples include remote controls, games and toys, calculators, keychain flashlights, watches, flashing shoes and clothing, musical greeting cards, cameras, flameless candles, and holiday ornaments.

The August 2022 law under which the CPSC is promulgating these rules provides that (1) the safety standard will not apply to any toy in compliance with the battery accessibility and labeling requirements of 16 CFR 1250 and (2) the packaging requirements will not apply to button cell or coin batteries in compliance with the marking and packaging provisions of the ANSI Safety Standard for Portable Lithium Primary Cells and Batteries (ANSI C18.3M).

Consumer products containing button cell or coin batteries that are manufactured or imported after Oct. 23 must comply with the safety standard rule. However, in recognition of limited testing availability and to avoid hardship, the CPSC will exercise enforcement discretion for 180 days (through approximately March 20). Third-party testing and certification of children’s products subject to this rule will be required as of Dec. 20.

The packaging rule will be effective Sept. 21, 2024. Button cell or coin battery packaging manufactured or imported after that date must comply with this rule.

For more information on compliance with this and other product safety standards, please contact Beth Ring at (212) 549-0133 or Ned Steiner at (202) 730-4970.

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