Part 1263 – Safety Standard for Button Cell Batteries: A Complete Guide

Part 1263 sets safety requirements concerning button cell batteries and coin batteries. The standard applies both to consumer products that contain such batteries and battery packaging. Ensuring compliance requires that the product battery compartment is designed according to certain mechanical safety requirements and that warning labeling is affixed to the product and packaging.

What is 16 CFR Part 1263?

Part 1263 establishes safety and warning requirements for button cell batteries and products that contain such batteries. The purpose of Part 1263 is to prevent children from accessing button cell batteries in both consumer products and battery packaging. If swallowed, button cell batteries can result in severe injury or even death.

Prior to Part 1263, toys and other children’s products were subject to button cell battery safety requirements. That said, other products that contain such batteries also pose a serious risk to children.

Part 1263 plugs that gap by setting safety and labelling requirements for other consumer products as well, including those that are not intended for children in any way.

Which batteries are covered by Part 1263?

Part 1263 covers button cell and coin batteries, which are defined as follows:

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(1) A single cell battery with a diameter greater than the height of the battery; or

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

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Here are some examples of button cell battery models:

• CR1216
• CR1220
• CR1225
• CR1616
• CR1620
• CR1632
• CR2016
• CR2025
• CR2032
• CR2325
• CR2330
• CR2430
• CR2450
• CR3032

Which products are covered by 16 CFR Part 1263?

The scope of Part 1263 states that it establishes requirements for:

Consumer products containing button cell or coin batteries

This covers any consumer product that is designed to contain at least one button cell battery. Note that products sold without batteries are also covered by Part 1263. What matters is that the product is designed to contain button cell batteries.

Packaging of button cell or coin batteries, including button cell or coin batteries packaged separately with a consumer product

This refers to packs of button cell batteries sold separately. These are also subject to certain requirements under Part 1263.

What are the requirements under Part 1263?

Part 1263 mainly covers two aspects of battery safety:

Consumer Product Battery Compartments

Consumer products designed to contain button cell batteries must comply with ANSI/UL 4200A. This standard sets requirements for battery compartment safety, which aims to ensure that children cannot easily access and swallow button cell batteries inside consumer products.

For example, a remote control battery compartment must be designed according to certain mechanical safety principles, which are specified under ANSI/UL 4200A.

Button Cell Battery Packaging Warnings Labels

Packaging containing button cell or coin batteries must carry a warning symbol and warning text.

Source: 16 CFR Part 1263

The standard also contains information about the size and placement. Note that there are different versions of the warning displayed above.

ANSI/UL 4200A Requirements

The CPSC mentions that ANSI/UL 4200A sets the following requirements:

1. Battery compartments must only be opened using a tool or two independent and simultaneous hand movements (the Apple AirTag is a good example of how this can work in practice)

2. Battery compartments must be able to withstand impacts to ensure that batteries do not detach and fall out

3. Warning affixed to the packaging

4. Warning affixed to the product

5. Warning affixed to user instructions

Note that we do not share information directly from the UL standard itself. However, a read-only version is available.

Why are there different requirements for products and packaging?

Small children cannot understand warnings, and it is therefore critical that products are safely designed. That said, batteries placed in product packaging or sold separately are removable even for children, which is likely the reason that they decided to focus on warning labels for this specific case.

What are some examples of consumer products containing button cell or coin batteries?

Here are some examples of consumer products that may contain button cell or coin batteries:

• Quartz watches
• Remote controls
• Digital scales
• Digital thermometers
• Fitness trackers

Are toys covered by 16 CFR Part 1263?

Toys are exempt from the requirements of Part 1263 as toys are already subject to battery safety requirements and labelling under ASTM F963 and CPSIA.

Is Part 1263 applicable if we do not include batteries?

Yes, Part 1263 explicitly states that its requirements apply to consumer products regardless of whether batteries are included with the product or sold separately.

Are there any exemptions?

Part 1263 mentions that toys, for the reason explained above, and zinc-air button cell batteries are exempt. The latter is deemed not to present an ingestion hazard.

Product testing

Part 1263 does not explicitly mention testing. That being said, it is often necessary to arrange third-party lab testing to verify that the battery compartment of the product complies with ANSI/UL 4200A.

Is a General Certificate of Conformity (GCC) required for products covered by Part 1263?

Yes, the CPSC states that a General Certificate of Conformity (GCC) is required for products covered by Part 1263. A General Certificate of Conformity (GCC) is normally issued by the US manufacturer or importer and contains the following information:

• Identification of the product covered by this certificate
• Citation to each CPSC product safety rule to which this product is being certified
• Identification of the domestic manufacturer or importer certifying compliance of the product
• Contact information for the individual maintaining records of test results
• Date and place of manufacture
• Date(s) and place(s) of testing
• Identification of any third-party laboratory that conducted the testing

What is the difference between Reese’s Law and 16 CFR Part 1263?

Reese’s Law essentially mandates that a standard covering battery safety and labelling requirements must be created. This eventually resulted in Part 1263, which has been in effect since October 2023.

Additionally, it requires packaging for button cells or coin batteries to follow the requirements set in 16 CFR Part 1700.15 – Poison prevention packaging standards.

Does Amazon require compliance with Part 1263?

Yes, Amazon requires that all consumer products, excluding toys, which are subject to different battery requirements, comply with the requirements under Part 1263.

We are aware of many instances in which Amazon removed products for which compliance with Part 1263 and ANSI/UL 4200A could be demonstrated.

If you intend to sell products containing button cell batteries on Amazon, then you need to be prepared to present the following:

1. ANSI/UL 4200A test reports

2. Warning label photos

3. General Certificate of Conformity (GCC)