Mass Delisting of Battery-Containing Products on Amazon US

Recently, Amazon has suddenly tightened compliance audits for battery-related products (including standalone batteries and battery-integrated devices), leading to mass delistings due to non-compliance.

Products such as calculators, remote controls, and musical greeting cards containing button cells or lithium batteries have been heavily affected. Even some non-battery products in categories like baby care and toys have been unexpectedly implicated. More critically, Amazon has closed the appeal channels, explicitly stating that "no documents will be reviewed."

Self-Inspection and Rectification Checklist for Sellers

Product Qualification & Certification

【Lithium Battery Products】

▪ UL certification: Required testing reports include ul2054 (rechargeable battery packs), ul1642 (battery cells), and ul2056 (power banks), issued by ISO 17025-accredited laboratories.

▪ Transportation Documents: un38.3 test report (for air and sea transport safety) and MSDS (Material Safety Data Sheet).

【Button/Coin Batteries】

▪ UL4200A Testing: Demonstrates child-resistant battery compartment design (e.g., requires a tool to open).

▪ gcc certificate: General Certificate of Conformity indicating compliance with UL4200A standard.

EU EPR Registration

▪ Scope: Required for sellers who sell batteries or battery-containing products in the EU (including direct-shipping sellers from China).

▪ Registration Timelines: Varies by country; due to long processing periods, sellers are advised to plan ahead.

▪ Submission Path: Upload EPR registration numbers via “Regulatory Compliance” or “Submit Compliance Documents” in the Amazon Seller Central backend.

Labeling & Packaging Requirements

▪ CE Mark + EU Representative Info: For EU listings, packaging/instructions must clearly show CE marking and EU rep info, which must also be linked to the store.

▪ Warning Labels: Button battery products must include choking hazard warnings in the local language. Check packaging and manuals for child safety warnings in English, and ensure the battery compartment requires tools to access.

Prohibited Product Types

▪ Standalone Cylindrical Lithium Batteries: Models like 18650 and 21700 are banned on Amazon US, CA, and AU. Even mentions in the product listing can lead to delisting.

▪ Unsealed Battery Packs: Removable and unsealed built-in batteries are classified as high-risk and are prohibited.

UL4200A Testing Requirements

Product Structure

1. For end products with "user-replaceable or movable batteries":

 ① The IEC61032 probe No. 11 must not be able to touch the battery. If the enclosure can be opened without tools or with fewer than two independent sequential actions by hand, it must be opened for evaluation.

 ② The product must be designed to prevent children from removing the battery, using methods such as:

- Requiring tools (screwdriver, coin) to open the battery compartment with at least 0.5 Nm torque and 90° rotation, or screws engaging at least two full threads;

- If using hands only, the compartment must require at least two independent and simultaneous actions to open.

 ③ If secured with screws or fasteners, they must remain attached to the lid/door (e.g., captive screws).

2. For products with "non-user-replaceable batteries":

 ① The battery must be completely enclosed and not accessible;

 ② Or be permanently fixed via soldering, riveting, or similar means.

Testing Requirements

▪ Structural Compliance

▪ Preconditioning Tests

▪ Abuse Tests (Drop, Impact, Crush, Torque, Pull, Pressure, Compliance)

▪ Safety Testing

▪ Product & Packaging Labeling Requirements

▪ Instruction Manual Requirements

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