ANSI/UL 4200A-2023 Labeling Requirements

Origin of the ANSI/UL 4200A-2023 Regulation

- On August 16, 2022, U.S. President Biden signed the Reese’s Law, which aims to reduce or eliminate the risks posed by button or coin batteries to children aged six and under.

- On February 9, 2023, the U.S. Consumer Product Safety Commission (CPSC) issued a rulemaking notice, establishing safety standards and labeling requirements for button batteries and products containing them.

- On September 11, 2023, ANSI/UL 4200A-2023 was officially voted in as the safety standard for button and coin battery products, set to take effect on March 19, 2024.

Products Affected

- Children’s products with button batteries (non-toy): Must undergo 16 CFR 1263 testing and be tested by a CPSC-approved third-party laboratory.

- General products with button batteries: Must undergo 16 CFR 1263 testing but do not require testing by a CPSC-approved lab.

- Impact on AV and ICT industries: Audio-visual (AV), consumer electronics, and information technology (IT) equipment are classified as general products using button batteries, but may be affected if they do not comply with UL 4200A. Manufacturers and importers are obligated to comply with U.S. laws, ensuring products meet UL 4200A design and labeling requirements.

Requirements in ANSI/UL 4200A-2023

1. Structural Testing: Verifies that the product design effectively reduces the risk of children accessing and swallowing the batteries. Accessible batteries must ensure battery compartment safety, and non-accessible batteries must be securely fixed.

2. Performance Testing:

   - Pre-treatment (e.g., stress release, battery replacement, etc.)

   - Abuse tests (drop, impact, crush, torsion, pull tests, etc.)

3. Packaging and Product Labeling: Labels must be durable and include a product instruction manual.

ANSI/UL 4200A-2023 Labeling Requirements

- If space allows, use the Figure 7C.1 label on the product body.

- If space is limited, use the Figure 7C.2 label (at least 7x9mm in size).

- If there is no space on the product body, labels must be placed on the packaging or provided via hang tags with full warning labels.

Mandatory Information in ANSI/UL 4200A-2023

- The product detail page must include:

  - Product model

  - Safety manual

  - General Certificate of Conformity (GCC)

  - Test report conforming to ISO 17025 and product images

- Packaging must comply with 16 CFR 1700.15 requirements.

ANSI/UL 4200A-2023 Implementation Timeline

- March 19, 2024: Manufacturers and importers must demonstrate compliance with CFR 16 Part 1263.

- September 21, 2024: Labeling requirements for individual button battery packaging will be officially enforced.

Recommended Actions

- Review the testing and labeling requirements under 16 CFR 1263 and UL 4200A.

- Inspect product structural designs and labeling to ensure compliance.

- Prepare necessary documentation and test reports before the effective dates.

Laws and Requirements in Other Countries and Regions

- United States: ASTM F963-23 for toys, and other button battery products under 16 CFR 1263 (UL 4200A-2023)

- European Union: Electric toy safety standard EN IEC 62115

China’s JJR is an ISO/IEC 17025 accredited laboratory providing services related to ANSI/UL 4200A-2023. The cost is USD 698, with a one-week turnaround. Inquiries are welcome!