Amazon UL4200A GCC Test Report Certificate

Amazon's new requirement for the US site mentions that if sellers are selling products with button batteries, they need to provide the following documents to ensure compliance:

- Proof from an ISO17025 accredited laboratory that meets Underwriters Laboratories 4200A (UL4200A);

- A general certificate of conformity (GCC) that meets UL4200A.

Amazon also mentioned that this requirement used to apply only to button or coin batteries themselves. For safety reasons, this law now applies to both the batteries and all consumer products containing these batteries. If valid compliance documents are not provided, the corresponding items will be prohibited from being displayed.

What is a GCC Certificate?

A GCC is a certificate in written form issued by the manufacturer or importer of general-purpose products (non-children's products) that certifies the product complies with applicable safety rules. Essentially, the GCC is a self-declaration from the manufacturer or importer stating that the product has been tested and complies with relevant CPSC and ASTM safety standards.

ANSI/UL4200A-2023 is the standard for issuing the GCC certificate.

What is UL4200A?

Due to children in the United States swallowing button batteries, in September 2023, the US Consumer Product Safety Commission (CPSC) voted to approve UL 4200A-2023 as the mandatory consumer product safety standard for products containing button batteries, codifying it into 16 CFR part 1263. Similarly, this standard update notice applies to consumer products using button or coin batteries.

UL4200A is designed to assess the use risks of consumer products containing button/coin batteries, considering the risk of children coming into contact with and ingesting the batteries during everyday use. UL 4200A systematically requires products containing button batteries to meet standards in terms of structure, testing, warning labels (on the product and packaging), instructions, etc.

Amazon's Button Battery or Coin Battery Consumer Products

Amazon requires all consumer products containing button batteries or coin batteries that fall under 16 CFR part 1263 to be tested and comply with the following regulations, standards, and requirements.

Consumer products containing button batteries include but are not limited to: calculators, cameras, electronic candles, flashing clothing, shoes, holiday decorations, keychain flashlights, musical greeting cards, remote controls, clocks, quartz watches, and GPS trackers.

Regulatory Standards for Consumer Products Containing Button or Coin Batteries

All of the following:

- 16 CFR part 1263 - Safety Standard for Button or Coin Batteries and Consumer Products Containing Such Batteries

- ANSI/UL 4200A (Safety Standard for Products Containing Button or Coin Batteries)

It is worth noting that the new CPSC regulations further expand the mandatory use of UL4200A. Products using flat round button batteries are covered by these standards, regardless of whether the button batteries are replaceable or rechargeable.

Action Required Upon Receiving Compliance Requests

The immediate effect of the new regulations has caused urgency among many sellers. Without valid compliance documents, product listings will be removed by Amazon. Since the survival of the listings is at stake, sellers are consulting peers on how to proceed and if anyone has successfully resolved this issue.

Sellers who receive compliance requests submit the required documentation in the backend, which includes a GCC certificate and UL4200A report, where the report must reflect:

- Safe battery compartment test: The product must have a child-resistant battery compartment to prevent child access.

- Warning labels: The packaging and the product itself must have clear warnings about potential choking hazards and the risks associated with battery ingestion.

Required Information

You must have this information, and Amazon will ask you to submit it. Therefore, it is advisable to keep this information readily accessible.

- Product detail pages for button batteries, coin batteries, and consumer products containing button or coin batteries must display the product model.

- Safety instructions and user manuals for button batteries, coin batteries, and consumer products containing button or coin batteries.

- General certificate of conformity: This document must state compliance with UL 4200A and be based on test results proving conformance to UL 4200A requirements.

- Testing conducted by an ISO 17025 accredited laboratory confirming compliance with UL 4200A, which has been adopted into 16 CFR part 1263 (Safety Standard for Button or Coin Batteries and Consumer Products Containing Such Batteries).

- The test report must include product images to verify that the tested product matches the product listed on the detail page.

- Product images proving compliance with the following requirements:

  - Poison prevention packaging requirements (16 CFR part 1700.15)

  - Warning label statement requirements (Pub. L. No. 117-171)

  - Safety standards for button or coin batteries and consumer products containing such batteries (16 CFR part 1263)

Action Steps for Amazon's New Regulations:

1. If the product contains button batteries:

   - Submit a GCC certificate (stating that the product has passed the UL 4200A standard test).

   - Provide an image of the product packaging with a barcode (must include warning labels about ingestion hazards).

   - Provide a UL 4200A test report approved by ISO17025 (including product images to prove it matches the listing).

2. If the product does not contain button batteries:

   - Review the listing for sensitive words and then file an appeal.

   - Primarily declare the product's use, materials, and clarify to consumers that it does not contain button batteries, generally passing without needing to provide additional proof.

How to Submit Compliance Documents on Amazon:

- Go to the [Performance] tab and select [Account Health].

- Under [Manage Your Compliance] in the lower right corner, click [Product Compliance Requests]. To provide documents, click [Provide Documents], or to appeal, click [Appeal Request] and select the appropriate [Appeal Reason] from the drop-down menu.

- To upload documents, drag and drop the files or open the browse window to select files.

- Click [Submit] to send your submission for Amazon's review.

In conclusion, this certification process is not particularly difficult and is relatively easy to pass. The key concern is how to handle the inventory that has not been sold yet. If the previously sent inventory needs to be removed, the losses could be substantial. Therefore, it is important to start the certification process promptly.