If you are a manufacturer of a consumer product that uses small batteries – often called “button cell” or “coin” batteries – you have until March 24th of next year to comply with a new Consumer Product Safety Commission (CPSC) final rule. The rule applies to just about everything having to do with these batteries; including their construction, performance, labeling, and certification. Another CSPC rule also mandates additional labeling requirements for the products containing them. The CPSC essentially adopted ASNI/UL 4200A-2023, which has been in place for a number of years, as the mandatory safety standard for button cell and coin batteries. 

The safety requirements in the CPSC rule were promulated pursuant to Reese's law, enacted in August of 2022. The law is named after Reese Hamsmith, an 18-month old who swallowed a button battery. Its intention is to protect children 6 years old and younger against the risks associated with the ingestion of these small batteries. The CPSC's action is essentially an extension of the principles embodied in Reese's law.

In addition, Section 3 of Reese’s law is effective now. It requires button cell and coin batteries individually sold and packaged separately with a product to comply with the Poison Prevention Packaging Act.

Manufacturers of products effected by this rule must act now to ensure compliance with the rule by the March 24th deadline. Indeed, in the coming months CPSC may also adopt consumer notification requirements which would mandate the publication of specific battery safety information on product manufacturer websites that are accessible to purchasers.