On September 21, 2023, the U.S. Consumer Product Safety Commission (CPSC) issued a direct final rule adopting the voluntary standard ANSI/UL 4200A-2023 as a mandatory consumer product safety rule for consumer products containing button batteries or coin batteries . This direct final rule becomes effective on October 23, 2023 , unless the Commission receives a material adverse opinion before October 5, 2023. If the Commission receives such comments, it will publish a document in the Federal Register withdrawing this direct final rule before its effective date.
Regarding compliance and implementation dates, third-party testing and certification of children’s products subject to this rule will not be required until December 20, 2023. Consumer products containing button or coin batteries manufactured or imported after October 23, 2023 are subject to this direct final rule. However, taking into account the limitations on test availability and to avoid difficulties, the Commission approved a 180-day transition period from September 21, 2023 to March 19, 2024, during which it can be implemented at its discretion.
In accordance with standard ANSI/UL 4200A-2023, products containing coin or coin batteries must meet the construction, performance, and labeling requirements in this standard to minimize the risk of exposure to and ingestion of coin or coin batteries by children. The main concerns of this standard are as follows:
1. Structure
❖For products containing removable coin or coin cells, the case of the coin cell or coin cell must be designed to require the use of a tool or require two separate, simultaneous actions to open or remove .
❖For products containing non-replaceable button batteries or coin batteries, they should be designed to have a closed case or a similar method that can withstand relevant performance tests so that the button batteries or coin batteries cannot be reached by children, or by using welding, rivet type fasteners or Completely secure the shell in the same way .
2.Performance
The button cell or coin cell battery contained in the product shall not pose a risk of unintentional contact by children. It shall comply with the performance tests set forth in this standard, including pre- processing of the product, abuse testing (drop test, impact test, squeeze test, torque test, Tensile testing and pressure testing) and safety testing .
3.Identification
All warning statements or icons on products, packaging and instructions should be eye-catching, clear, easily legible under normal lighting conditions, and safely marked .