Compliance Tips for Button & Coin Cell Batteries on Amazon US

Amazon US has issued a notice requiring sellers to comply with the new packaging and warning label regulations for button and coin cell batteries. If you sell standalone button and coin cell batteries on Amazon, starting from March 2, 2023, you need to prove that your products meet the child-resistant packaging and warning label requirements. It is expected that federal standards for button batteries, coin cell batteries, and consumer products containing them will be issued by August 15, 2023. Amazon's policy may eventually cover other products with button or coin cell batteries to comply with the Reese's Law.

Core Regulatory Requirements & Applicable Products

1. Regulatory Background

Pursuant to the U.S. Reese's Law (H.R.5313), effective February 12, 2023, all packaging for button batteries (with a diameter of 5–25mm and height of 1–6mm) and coin cell batteries must pass child-resistant packaging testing to prevent accidental ingestion by children.

Mandatory Standards

①　16 CFR 1700.15 (Child-Resistant Packaging Standard): Requires packaging to pass child-resistance testing (85% of children cannot open the package within 10 minutes).

②　16 CFR 1700.20 (Testing Procedures): Specifies laboratory testing methods.

③　ANSI C18.3M (Battery Core Safety Standard): Defines safety, performance, and environmental adaptability tests for button batteries.

Amazon Policy Requirements

All button and coin cell batteries must be tested and comply with the following regulations, standards, and requirements:

①　16 CFR Part 1700.15 (Child-Resistant Packaging Standard);

②　16 CFR Part 1700.20 (Special Packaging Testing Procedures);

③　ANSI C18.3M (Safety Standard for Portable Lithium Primary Batteries).

2. Scope of Applicable Products

①　Standalone button/coin cell batteries for sale.

Note: Products containing button batteries (e.g., remote controls, watches, greeting cards, electronic scales, etc.) must comply with UL 4200a and 16 cfr 1263 standards.

Detailed List of Relevant Testing Standards

Full Process & Timeframe for Qualification Certification

Key Steps

1. Select a Laboratory: Choose a lab with ISO 17025 accreditation, such as JJR LAB.

2. Submit Test Samples: Generally, 1 unopened finished product + 1 button battery (with complete packaging and warning labels) are required.

3. Testing Content:

①　Child-Resistance Test: Simulates the failure rate of children attempting to open the packaging.

②　Adult-Use Test: Ensures adults can open the packaging normally.

③　Warning Label Inspection: The label must include: DANGER: Ingestion may cause chemical burns, perforation, or death. Contains button battery — KEEP AWAY FROM CHILDREN! If swallowed, seek immediate medical attention (U.S. Poison Control Center: 1-800-222-1222).

Packaging & Labeling Compliance Tips

1. Mandatory Packaging Requirements

(1) Dual-Barrier Design: At least two layers of independent protection (e.g., shrink wrap + rigid outer box), which must pass compression and drop tests.

(2) Warning Labels:

①　A warning symbol (⚠, ≥6mm) and the statement “KEEP OUT OF REACH OF CHILDREN” must be printed on the front of the package.

②　For batteries with a diameter ≥20mm, warning labels must be printed directly on the battery body.

③　Regulatory number: The package must be marked with “Complies with 16 CFR §1700.15/20”.

Reference Warning Statement Examples

WARNING: INGESTION HAZARD: This product contains a button cell or coin battery. DEATH or serious injury can occur if ingested. A swallowed button cell or coin battery can cause internal chemical burns in as little as 2 hours. KEEP new and used batteries OUT OF REACH of CHILDREN. Seek immediate medical attention if a battery is suspected to be swallowed or inserted inside any part of the body.

WARNING: Death or serious injury can occur in as little as 2 hours if swallowed. Keep away from children, kept out of the reach of children. Keep in original package until ready to use. Dispose of used batteries promptly. Seek immediate help if swallowed. Call a local poison control center for treatment information. US:1-800-222-1222, CA:1-800-888-1222. Risk of fire and burns. Do not recharge, disassemble, heat above (manufacturer's specified temperature rating) or incinerate.

WARNING: INGESTION HAZARD: This product contains a button cell or coin battery. DEATH or serious injury can occur if ingested. A swallowed button cell or coin battery can cause internal chemical burns in as little as 2 hours. KEEP new and used batteries OUT OF REACH of CHILDREN. Seek immediate medical attention if a battery is suspected to be swallowed or inserted inside any part of the body. For treatment information call [phone number for the National Battery Ingestion Hotline, currently 1-(800) 498-8666].

Amazon Audit Document Checklist

Prepare the following English documents in advance:

1. Test Report: Issued by an ISO 17025-accredited laboratory, covering 16 CFR 1700.15/20 and ANSI C18.3M standards, and must include a comparison between sample photos and actual product photos.

2. Product Information:

①　High-definition six-sided packaging images (including warning labels);

②　Product manual (if available).

Note: The report must indicate that "the tested product is consistent with the product displayed on the sales page"; otherwise, the audit application is likely to be rejected.

Common Reasons for Audit Rejection

①　The test report does not include physical product images, or the images are blurry;

②　Missing warning statements or regulatory numbers on the packaging;

③　The testing laboratory does not hold ISO 17025 accreditation;

④　Failure to provide images showing product labels, relevant safety information, compliance marks, hazard warnings, and all sides of the product packaging;

⑤　Product images do not serve as valid evidence for meeting child-resistant packaging requirements (16 CFR Part 1700.15);

⑥　Product images do not serve as valid evidence for meeting preventive labeling requirements (Public Law No. 117-171).