UL 4200A-2026 Compliance Standard for Button/Coin Cell Batteries

On September 2, 2026, the US Federal Register published a notice from the Consumer Product Safety Commission (CPSC) (Docket No. CPSC-2023-0004). The CPSC is seeking public comments on UL 4200a-2026, a revised version of the voluntary standard UL 4200A Standard for Safety for Products Incorporating Button Batteries or Coin Cell Batteries, which is referenced in its mandatory rule.

For enterprises exporting products containing button/coin cell batteries to the United States—such as toys, consumer electronics, luminaires, remote controls, key fobs, clocks and watches, and calculators—as well as battery packaging-related enterprises, this is a compliance update that requires continuous tracking.

Note: This article is compiled based on the content published in the US Federal Register on September 2, 2026. Its core focuses on the CPSC's notice regarding the revised version of UL 4200A. This article does not constitute legal advice; specific requirements are subject to the official original text and the final decision of the CPSC.

Regulatory Background

The US Reese's Law aims to protect children aged 6 and under from the hazard of ingesting button cell or coin batteries under reasonably foreseeable use or misuse conditions.

According to the law:

• "Button cell or coin battery" is defined as:

1. A single cell battery with a diameter greater than its height; or

2. Any other battery determined by the CPSC to pose an ingestion hazard, regardless of its technological type.

• The CPSC must promulgate a rule to establish warning label requirements for consumer products containing button/coin cell batteries, as well as for the packaging of button/coin cell batteries.

• Warning labels must:

1. Clearly identify the ingestion hazard;

2. To the extent practicable, instruct consumers to keep new and used batteries out of the reach of children, to seek immediate medical attention if a battery is ingested, and to follow other consensus medical advice.

Based on this, the CPSC issued a mandatory safety rule, codified in 16 cfr part 1263, which incorporates ANSI/ul 4200a-2023 (approved on August 30, 2023) with additional requirements. The rule was published on September 21, 2023 (see 88 FR 65274 and 88 FR 65296).

This mandatory standard includes:

• Performance requirements

• Testing procedures

• Warning label requirements

• Instruction manual requirements

Standard Revision Updates

UL has notified the CPSC that it has approved and published a revised version of the voluntary standard, UL 4200A-2026.

The CPSC is currently evaluating this revision to determine whether it improves the safety of button/coin cell batteries and consumer products containing such batteries. As of the compilation of this article, the public comment period has closed.

Key Points of the Legal Process

According to Section 2(f) of Reese's Law:

1. When a voluntary standards organization revises a standard, it must notify the CPSC.

2. Upon receiving the notification, the CPSC may reject or accept the revised standard, in whole or in part.

3. If the CPSC intends to reject it, it must notify the voluntary standards organization within 90 days of receiving the notification, stating that the revised standard, in whole or in part, does not improve safety, and retain the existing standard, in whole or in part.

4. If the CPSC does not take action to reject it, the revised voluntary standard will be considered a consumer product safety standard issued under Section 9 of the Consumer Product Safety Act (CPSA). It will take effect 180 days after the CPSC receives the revision notice, or on a later date specified by the CPSC in the Federal Register.

Therefore, although the CPSC is still evaluating, enterprises cannot merely wait for the final conclusion. If the revision is not rejected, it may become a mandatory referenced standard in the future, impacting product testing, labeling, instruction manuals, and packaging compliance.

Corporate Response Recommendations

1. Confirm whether the product falls under the scope of 16 CFR Part 1263

• Does it contain button cell or coin batteries?

• Is it classified as a consumer product?

• Does it involve button/coin cell battery packaging?

2. Check existing compliance documents

• Existing UL 4200A-2023 test reports

• Warning labels, instruction manuals, and packaging markings

• Structural safety and performance test records

3. Obtain and study the original text of UL 4200A-2026

• Compare the revised content

• Evaluate the impact on existing product design, labeling, and testing items

4. Track the CPSC's final decision and effective date

• Monitor the 90-day rejection period and the 180-day effective period

• Pay attention to whether the CPSC specifies a later effective date in the Federal Register

5. Plan ahead for difference testing and certification updates

• Communicate with testing and certification bodies

• Assess whether supplementary testing or updated reports are needed

• Avoid risks of customs clearance failures, delistings, or product recalls caused by standard updates