In September 2023, the CPSC (U.S. Consumer Product Safety Commission) passed a resolution making the UL 4200A-2023 standard a mandatory consumer product safety regulation. Based on the UL 4200A test results, a General Certificate of Conformity (GCC) is issued, applicable to consumer products containing button batteries to reduce the risk of children aged 6 and under swallowing these batteries. The related requirements are also incorporated into 16 CFR 1263 and will be enforced starting March 19, 2024.
According to the policy, Amazon U.S. has implemented relevant review requirements for button batteries, coin batteries, and products containing such batteries since April 8, 2024.
Key Points:
- All products containing button batteries must meet the UL 4200A standard to be exported to the United States.
- The UL 4200A standard applies to all products containing button batteries, regardless of whether the batteries are replaceable or rechargeable.
- Applicable button and coin batteries: This policy applies to flat, round, single-unit button and coin batteries with a diameter typically ranging from 5 to 25 millimeters and a height between 1 to 6 millimeters, as well as consumer products containing these batteries.
- Button batteries are typically powered by alkaline, silver oxide, or zinc air and have a lower voltage rating (usually 1 to 5 volts). Coin batteries are powered by lithium, with a voltage rating of 3 volts and are generally larger in diameter than button batteries.
Amazon requires all button and coin batteries to be tested and meet the following regulations, standards, and requirements:
- 16 CFR Part 1700.15 (Poison Prevention Packaging Standards)
- 16 CFR Part 1700.20 (Special Packaging Testing Procedures)
- ANSI C18.3M (Safety Standard for Portable Lithium Primary Cells and Batteries)
Amazon requires all consumer products containing button or coin batteries and falling within the scope of 16 CFR Part 1263 to be tested and meet the following regulations, standards, and requirements:
- 16 CFR Part 1263 — Safety Standard for Button or Coin Batteries and Consumer Products Containing Such Batteries
- ANSI/UL 4200A — Safety Standard for Products Containing Button or Coin Batteries
Your product detail page must include the following information:
- The model number of the product containing button and coin batteries.
- Product safety instructions and user manuals for products containing button or coin batteries.
- General Certificate of Conformity: This document must list compliance with UL 4200A and demonstrate compliance based on test results.
- Testing performed by an ISO 17025 accredited laboratory confirming compliance with UL 4200A, which has been adopted by 16 CFR Part 1263.
- The test report must include product images to prove that the tested product matches the one published on the product detail page.
- Product images demonstrating compliance with the following requirements:
- Poison prevention packaging requirements (16 CFR Part 1700.15)
- Warning label statement requirements (Public Law 117-171)
- Safety standards for button or coin batteries and products containing such batteries (16 CFR Part 1263)
Product Body:
If there is enough space on the product body, use label Figure 7C.1:
If space is limited, use label Figure 7C.2 with minimum dimensions of 79mm. The meaning of this symbol must be explained in the product manual or other printed materials or tags accompanying the product.
If the product body does not have enough space for label Figure 7C.1 or Figure 7C.2, the product packaging must comply with packaging warning label requirements, or use a tag to include the full packaging warning label requirements.
Note: Regardless of space on the body, packaging warning labels are necessary.
Product Packaging:
If there is enough space on the product packaging, attach one of the following labels, Figure 7B.1 or Figure 7B.2:
For products without packaging, create a tag or attach it to the product.
If the packaging space is limited, attach Figure 7B.3 and use Figure 7B.4 in the next available space. Note that using only one is insufficient.
Minimum dimensions for the icons are 79mm, and warning statements can be listed and printed.
Notes:
1. When the label has multiple colors, ensure the colors match the specific colors on the warning label.
2. The icon in Figure 7C.2 must be at least 7mm wide and 9mm high, and the icon in Figure 7B.2 must be at least 8mm in diameter.
3. Labels must use the official language of the country where the product is sold; if there is no official language, use English.
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