What is 16 CFR Part 1700.15 Testing Standard?

Amazon US has announced that sellers must comply with new packaging and warning label requirements for button and coin batteries.

If you sell individual button or coin batteries on Amazon, starting March 2, 2023, you must prove compliance with child-resistant packaging and warning label requirements.

It is expected that federal standards for button batteries, coin batteries, and consumer products containing themwill be issued by August 15, 2023. Amazon’s policy may ultimately cover other products containing button or coin batteries to comply with the Bobby’s Law.

Core Regulatory Requirements and Applicable Products

1. Regulatory Background

According to the Bobby’s Law (H.R.5313, USA), from February 12, 2023, all button batteries (diameter 5–25mm, height 1–6mm) and coin batteries must have packaging that passes child-resistant packaging teststo prevent accidental ingestion by children.

Mandatory Standards:

①　16 CFR 1700.15 (Poison Prevention Packaging Standard):Packaging must pass child-resistance testing (85% of children cannot open within 10 minutes).

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

③　ANSI C18.3M (Battery Safety Standard):Covers battery body safety.

2. Scope of Applicable Products

Button or coin batteries sold individually.

Note:Products that do not contain such batteries (e.g., remote controls, watches, greeting cards, electronic scales) follow ul4200aand 16 cfr 1263standards instead.

Full Qualification Process & Timeline

Key Steps

1. Select a Laboratory:Must be ISO 17025 accredited.

 Example: China JJR lab – \~\$698, turnaround 5–7 business days.

2. Submit Samples:Usually 1 unopened finished product + 1 button battery (complete packaging with warning label).

3. Batch Testing:Batteries of the same type can be tested together; different models must be listed separately (e.g., CR series, LR series).

Testing Contents

①　Child-Resistance Test:Simulates children attempting to open the package.

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

③　Warning Label Check:Must include statements such as:

DANGER: Swallowing may cause chemical burns, perforation, or death.

Contains button battery – Keep away from children!

If swallowed, seek medical attention immediately (US Poison Control Center: 1-800-222-1222).

Packaging & Labeling Compliance Tips

1. Packaging Mandatory Requirements

Dual-Layer Barrier Design:At least two separate protective layers (e.g., shrink wrap + rigid outer box), capable of passing compression and drop tests.

a.        Warning Labels:

①　Front packaging must display a ⚠ warning icon (≥6mm)and the text:

KEEP OUT OF REACH OF CHILDREN

②　For batteries ≥20mm in diameter, the battery itself must have a printed warning label.

b.       Regulation Reference:Packaging must indicate:

Complies with 16 CFR §1700.15/20

Amazon Review Document Checklist

Prepare the following in English:

1. Test Report:

①　Issued by an ISO 17025 lab.

②　Covers 16 CFR 1700.15/20 + ANSI C18.3M.

③　Includes sample and real product photo comparison.

2. Product Information:

①　Six-sided product packaging images (high resolution, with warning labels) 

②　Instruction manual (if available)

⚠ Note:The report must show that the tested product is identical to the product on the Amazon listing; otherwise, it is likely to be rejected.

Common Rejection Reasons & Solutions

Frequent Issues

(1)     Report does not include real product photos or images are unclear

(2)     Packaging missing warning text or regulation reference

(3)     Laboratory lacks ISO 17025 accreditation