Button Cell and Coin Battery Product Safety

Part 1263 concerns consumer products containing or designed to use button cell or coin batteries, with the rule’s definitions and exclusions applied. A button or coin cell generally has a diameter greater than its height; zinc-air batteries are excluded from this part’s scope. Devices supplied without batteries can still be designed to use them. Review the compartment and instructions rather than relying only on what is packed in the box.

The incorporated ANSI/UL 4200A-2023 provisions require replaceable-cell compartments to use a tool or the specified independent simultaneous hand movements for access. The product also undergoes the applicable use-and-abuse tests so that batteries cannot be accessed or released. A screw on a prototype is not enough evidence if the production closure, retention hardware or enclosure construction differs materially.

The product packaging, product marking where practicable, and instructions have applicable warning requirements. The separate battery-packaging provisions must also be considered. Inspect the artwork and physical placement, not only a supplier’s confirmation that a warning exists. A QR code or a general instruction to keep batteries away from children should not be assumed to replace a prescribed warning format.

Section 3 of Reese’s Law addresses special packaging for button and coin batteries, subject to its exceptions, while part 1263 includes battery-package warning provisions. These duties are not identical to testing an enclosed finished product. Establish whether the transaction supplies a device, loose replacement cells, batteries packaged separately with the device, or a combination, then assign the relevant packaging and certificate evidence.

Certain toys complying with the applicable toy-standard battery-accessibility and labeling provisions are excluded from the product standard under the stated conditions. That is not an exclusion for every item described as a toy. Determine the relevant CPC or GCC and testing basis for the actual article. Consult the regulation and CPSC guidance before applying another product’s report, toy exception or packaging citation.

Read the authorized incorporated UL text through the access information provided by CPSC. This record summarizes regulatory subjects rather than reproducing private test instructions. Passing part 1263 does not establish electrical, transport, radio or broader battery-safety compliance. Keep the enclosure, closure, cell type, warnings and production specification connected to the evaluated product and reassess changes that can release or expose the cell.