What is UL4200A-2023?

1. GCC Background

GCC's requirements stem from a serious safety incident in the US market. In 2020, a girl died in Texas after swallowing a button battery from a TV remote control. Since then, US regulators have voted to develop new safety standards for button batteries.

On September 11, 2023, the CPSC voted to adopt the voluntary standard ANSI/UL 4200a-2023 (Safety Standard for Products Containing Button Cells or Coin Cell Batteries) as the mandatory consumer product safety rule for consumer products containing button cells or coin cell batteries, to be codified in 16 CFR 1263.

CPSC has determined that the most recently updated ANSI/UL 4200A, dated August 30, 2023, meets the performance and labeling requirements of Section 2(a) of the Reese’s Law for consumer products containing:

Button cell or coin cell battery.

The Reese Act requires the CPSC to promulgate consumer product safety standards to eliminate or substantially reduce the risk of injury to children 6 years of age or younger from ingestion of button or coin-type batteries under reasonably foreseeable circumstances of use or misuse.

ANSI/UL 4200A-2023 covers the following requirements:

• Preprocessing requirements

• Abuse Testing

• Safety Testing

• Product and packaging marking requirements

• Instruction Manual Requirements

The scope of Reese's Law and 16 CFR part 1263 is broad and includes consumer products placed on the U.S. market with removable and non-removable coin or button batteries. These requirements affect any general use or children's product that uses such batteries, including single-cell batteries with a diameter that exceeds the height, or any other battery that the CPSC has determined presents an ingestion risk (toys and products for professional or commercial use are not subject to this restriction). Product categories include consumer electronics, information technology equipment, audio and video, durable goods, accessories, apparel, and footwear.

II. Regulatory requirements

Button cell battery definition: A "button cell or button cell" that complies with the requirements of 16 CFR part 1263 is a single-cell battery with a diameter greater than the height of the battery. (Consumer (household) products with button lithium batteries with a diameter ≤ 32mm and a diameter greater than the height (but some end product standards may have additional supplementary requirements).)

This rule excludes zinc-air coin cells, or button cells, from the scope of 16 CFR part 1263.

According to ANSI/UL 4200A-2023, the requirements for consumer products that contain or are designed to use button cells or coin-cell batteries are as follows:

• 1. Battery compartments containing replaceable button cells or coin-cell batteries must be secured so that they require a tool or at least two separate and simultaneous hand movements to open. Prevent small children from easily accessing the batteries.

• 2. Button cell batteries or button cell battery holders shall not be used or subjected to abuse testing that could result in such batteries being exposed or released.

• 3. The entire product packaging must carry a warning.

• 4. If practicable, the product itself must carry a warning.

• 5. Accompanying instructions and manuals must contain all applicable warnings

3. What products are subject to regulatory requirements for button batteries?

CR series: CR series button batteries are a common battery model. Among them, CR2032 has a diameter of 20mm, a thickness of 3.2mm, and a capacity of about 220mAh. It is mainly used in calculators, watches, scales and other equipment. The diameter of CR2016 is also 20mm, but the thickness is only 1.6mm, and the capacity is about 90mAh. It is often used in electronic toys, remote controls and other equipment.

LR series: LR series button batteries are alkaline batteries. For example, LR44 has a diameter of 11.6mm, a thickness of 5.4mm, and a capacity of about 150mAh, and is commonly used in devices such as watches and remote controls; while LR41 has a diameter of 7.9mm, a thickness of 3.6mm, and a capacity of about 25mAh, and is suitable for small electronic products such as assistive hearing devices and watches.

AG series: AG series button batteries are also common, such as AG3, AG10, AG13, etc. These batteries are usually used in toys and gifts.

SR series: Among the SR series button batteries, SR626SW is a silver oxygen battery with a diameter of 6.8mm, a thickness of 2.6mm, and a capacity of about 28mAh. It is commonly used in watches, electronic toys and other equipment;

4. What are the UL4200A:2023 safety standard requirements?

Abuse test: This part of the test simulates the abuse that button batteries may suffer, including dropping, impact, squeezing, twisting, pulling, compression, etc. The drop test requires the battery to be dropped from a certain height onto a hard board multiple times, the impact test involves applying impact force to the battery casing or battery cavity cover, and the crush test is to apply continuous pressure on the exposed surface of the battery with a certain force.

Battery compartment safety test: mainly tests the firmness of the battery compartment to prevent users from easily moving or replacing the battery. This is usually done by applying external force to test the firmness of the battery compartment to ensure that the battery does not separate during the test.

Labeling and marking requirements: UL4200A also specifies labeling requirements for products and packaging. These labels must be clear, permanent, and meet specific legibility standards. The label content should include warning information about battery safety to alert consumers, especially children, to the possible dangers.

5. What tests does the UL4200A:2023 safety standard include?

1. Abuse testing

◆ Portable products are dropped 3 times, and handheld products are dropped 10 times (each time from a height of 1 meter onto a horizontal hard surface).

◆ The outer shell or battery cavity cover and door must withstand a 2J impact test for 3 times.

◆ Rolling test: A force of 330N is applied to the exposed surface for 10 seconds, and the force is applied through a plane approximately 100mm x 250mm.

◆ After tests a, b, and c, apply a force of 45N for 10 seconds using the test rod 11 of IEC 61032. The battery must not become accessible. During the test, the battery compartment cover and door do not need to be opened and remain in normal function.

2. Installation firmness test

For the mounting security of "battery not removable or replaceable by the user", the battery shall not be detached by a hook using an outward force of 20 Newtons for 10 seconds.

Companies that produce or export button/coin batteries or products containing button/coin batteries should always pay attention to the updates of relevant standards, adjust production processes in a timely manner, strictly control product quality, and ensure that products meet relevant control requirements. If you have products containing button/coin batteries that need to enter the US market, you need to test them before providing them to consumers to prove that they meet safety standards. 

6. Warning label requirements:

● Clearly state the dangers of swallowing;

●Instruct consumers to keep new and used batteries out of the reach of children, whenever feasible, to seek medical attention immediately if a battery is accidentally ingested, and to follow any other consistent medical advice.

●Warning statements should be placed on the product packaging, instructions and battery box.

Example of warning on button battery packaging

Example of a warning on the packaging of a consumer product containing button batteries

Example of a warning on a consumer product containing a button battery

If there is insufficient space on the product to fit the warning above, the following warning should be used as an alternative:

Child-resistant packaging requirements

Not later than 180 days after the date of enactment of this Act (i.e., by February 12, 2023), any packaging for button cells or coin cells shall comply with 16 CFR §1700.15 (Standard for Poison-Resistant Packaging) and 16 CFR §1700.20 (Testing Procedures for Special Packaging).