What is the difference between ANSI C18.3M and UL4200A?

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

If you sell standalone button and coin batteries on Amazon, starting March 2, 2023, you will need to prove that your products meet child-resistant packaging and warning label requirements.

Applicable products include: standalone button cells or coin batteries, typically used as single-cell batteries to power watches, computer clocks, hearing aids, and other small devices. We at Huashang Testing have also received numerous inquiries from clients regarding this.

Background

On August 16, 2022, the U.S. President signed H.R. 5313, known as Reese's Law, into effect. The act requires the U.S. Consumer Product Safety Commission (CPSC) to establish safety standards for button or coin batteries, as well as consumer products containing such batteries, within no later than one year, in order to protect young children from button battery ingestion hazards.

On February 10, 2023, the CPSC issued notification G/TBT/N/USA/1964, announcing a Notice of Proposed Rulemaking (NPR) regarding packaging and safety standards for consumer products containing button or coin batteries.

Section 3(a) of Reese's Law stipulates that within 180 days after the enactment of the act (i.e., February 12, 2023), button or coin batteries sold, offered for sale, manufactured, commercially distributed, or imported into the United States must meet the requirements of 16 CFR 1700.15 and 16 CFR 1700.20, or other testing standard requirements prescribed by the Commission. However, according to Section 4 of Reese's Law, if button or coin batteries comply with the labeling and packaging provisions within the ANSI Safety Standard for Portable Lithium Primary Cells and Batteries (ANSI C18.3M), they may be exempted from the requirements of Section 3(a).

Applicable Product Scope

Reese's Law defines a "button cell or coin battery" as:

(A) A single cell battery with a diameter greater than its height; or

(B) Any other battery, regardless of the technology used to produce an electrical charge, that is determined by the Commission to pose an ingestion hazard.

The NPR focuses on the button and coin batteries described in Part (A), because other batteries with a diameter smaller than their height, such as AAA cylindrical batteries, do not pose the same type or degree of ingestion hazard as button or coin batteries.

Our Button and Coin Battery Policy

Amazon requires that all button and coin batteries be tested and comply with the following regulations, standards, and requirements:

Product regulations, standards, and requirements for button and coin batteries include the following two:

• 16 CFR Part 1700.15 (Poison Prevention Packaging Standards); and

• 16 CFR Part 1700.20 (Testing Procedure for Special Packaging)

Or the following one:

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

Note: The two standards, 16 CFR 1700.15 and 16 CFR 1700.20, are assessments for the packaging, while the ANSI C18.3M standard is an assessment for the battery itself. Conducting all three standards together constitutes a complete set. Different battery models must be tested separately and cannot be bundled together as a single series.

Labeling and Packaging Requirements for Button Batteries

Answer: Warning label requirements:

• Clearly state the ingestion hazard;

• Where 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 any other consensus medical advice.

• Warning statements should be placed on the product's packaging, instructional manuals, and the battery compartment.

Examples of Warning Statements on Button Battery Packaging:

Display warning information on the battery packaging, requiring spare batteries to be placed in high locations out of reach of young children, and for used batteries to be disposed of promptly. For example, include a warning phrase on the battery packaging similar to: "BATTERY WARNING: KEEP OUT OF REACH OF CHILDREN."

Display warning information on the battery packaging to remind consumers of the hazards such batteries may pose to young children.

Display warning information on the battery packaging providing explicit instructions similar to: "If you think batteries might have been swallowed or placed inside any part of the body, seek immediate medical attention." This explains the measures to take if it is suspected that a young child has swallowed a battery. The same warning information should be marked on the product packaging and in the instructions.

Required Information

You must be aware of this information. We may request you to submit this information at any time, so it is recommended that you have it ready for easy submission.

• Your company name (if applicable) and Seller ID

• Your contact information: email address and phone number

• A list of all button and coin batteries you have listed on the Amazon store

• The product name or model number displayed on the detail page of the button or coin battery

• Product instructions and manuals for the button and coin batteries

• Images showing the product label, relevant safety information, compliance marks, hazard warnings, and all sides of the product packaging

• A test report issued by an ISO 17025-accredited laboratory, proving that the product complies with the aforementioned regulations, standards, and requirements

• The test report must include images of the tested product to prove that it is identical to the product listed on the product detail page

• An approved General Certificate of Conformity / Certificate of Analysis (if applicable)

• Product images proving compliance with the following requirements:

• Poison prevention packaging requirements (16 CFR Part 1700.15)

• Safety labeling statement requirements (Public Law 117-171)