Button cell batteries can cause horrendous injuries if swallowed. In this guide, we list standards and regulations that apply to button cell batteries and products containing button cell batteries in the United States. Notice that standards, such as ASTM and UL standards, apply to both children’s products and non-children’s products.
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UL 4200A – Products Incorporating Button or Coin Cell Batteries of Lithium Technologies
UL 4200A is a voluntary standard intended to help reduce the risk of children swallowing button and coin cell batteries removed from products, such as electronic toys, clocks, or remote controllers.
UL 4200A applies household products intended to be used with lithium button or coin cell batteries, including:
- Remote control cars
- Talking plush toys
- Household electronics
The standard doesn’t apply to products for professional or commercial use, which are located in places where children are generally not present.
Ingestion Hazards Safety Requirements
Button and coin cell batteries can cause injuries such as choking, intestine erosion, or death if swallowed by children. Thus, keeping them securely within a toy or household item is a needed safety precaution.
This standard specifies dimensions (e.g. width, height) for lithium batteries that are incorporated in the toys to prevent children from inhaling them. It also covers instructions regarding the construction of products in order to prevent children from easily removing the button and coin cell batteries.
UL 4200A specifies the warnings for button and coin cell batteries such as the letters, font size, and wording. The goal is to warn users of the potential risks of the products for children.
If you want to learn more about UL 4200A, you can visit UL’s website.
UL 1642 – Standard for Safety Lithium Batteries
UL 1642 specifies safety requirements for primary (non-rechargeable) and secondary (rechargeable) lithium batteries. The purpose of the standard is to reduce the risk of fire or explosion of lithium batteries when they are used in a product, or removed from the product and discarded.
It covers testing standards, performance, and marking, regarding the safe use of lithium batteries, including button and coin batteries.
The safety requirements set forth within the UL 1642 standard apply to primary and secondary lithium batteries, including:
a. Lithium batteries replaceable by a technician that contain up to 5 grams of metallic lithium
b. Lithium-ion batteries replaceable by the user that contain up to 4 grams of metallic lithium-ion (and a maximum 1 gram of metallic lithium per electrochemical cell)
As said, UL 1642 covers the risk of fire and explosion and specifies testing standards for covered lithium batteries, including short-circuit test, crush test, and impact test. However, the standard doesn’t cover the risk of ingestion.
If you want to learn more about UL 1642, you can read this guide.
UL 2054 – Standard for Household and Commercial Batteries
UL 2054 is a standard intended to reduce the risk of fire or explosion when batteries are incorporated into products. The requirements of this standard apply to both rechargeable and non-rechargeable lithium-ion batteries.
Examples of batteries covered by this standard include:
- Button batteries
- Rechargeable batteries for remote controllers
UL 2054 covers testing methods of batteries for household and commercial use. The testing standards specified within UL 2054 include abusive overcharge test, limited power source test, and surface temperature test.
The purpose of conducting these tests is to observe the explosion possibility of the batteries when being crushed, heated, or dropped. You can learn more about battery testing methods in this article.
ASTM F963 – Standard Consumer Safety Specification for Toy Safety
ASTM F963 is a compulsory safety standard incorporated under the Consumer Product Safety Improvement Act (CPSIA), which covers products that are intended to be used by children under the age of 12 years.
ASTM F963 also covers toys that are operated with button and coin cell batteries, including safety labels, warning instructions, and design guidelines.
Importers and manufacturers of toys operated with button and coin batteries have the responsibility to minimize the risk of small parts ingestion hazards, including button and coin batteries.
As also explained in this CPSC guidance document, importers and manufacturers should ensure that the battery compartment is designed to avoid the easy removal of batteries from toys. For example, removing the battery from toys should require a screwdriver or two independent simultaneous motions.
Importers and manufacturers should also provide necessary warnings on the product, product packaging, or batteries (if applicable).
For example, as also outlined in the above-linked guidance document, they could add a removable safety tab with pictograms and an age warning sign on the battery. They can also stamp or etch the pictograms and warning information on the surface of the battery.
ASTM F2923 – Standard Specification for Consumer Product Safety for Children’s Jewelry
ASTM F923 is a standard that concerns the safety of children’s jewelry. The standard covers risks such as:
- Children swallowing small metals or other components, including batteries
- Children’s exposure to certain other chemicals in paints and surface coatings
- Children’s exposure to hazardous liquids
The standard sets out guidelines for children’s jewelry containing small size batteries that could cause swallowing risks to children. Such batteries should not be accessible to children.
Children’s jewelry containing batteries should also have a label with information concerning the appropriate use of the batteries, such as the type of models of batteries to use, and whether it is feasible to mix different models of batteries.
In addition, battery-operated children’s jewelry should also have a permanent polarity marking of the battery compartment. You can read this guidance document on ASTM F2923 to learn more.
Consumer Product Safety Improvement Act (CPSIA)
The CPSIA covers the safety of children’s products, including children’s products operated by or containing buttons and coin batteries. The CPSIA incorporates several safety standards developed by the ASTM regarding the safe use of button and coin batteries in children’s products.
Here we list some examples of mandatory ASTM standards covering button and coin batteries used in children’s products:
a. ASTM F963 – Standard Consumer Safety Specification for Toy Safety
b. ASTM F2923 – Standard Specification for Consumer Product Safety for Children’s Jewelry
Notice that these are the same standards already mentioned in this guide. However, we mention these standards again in the context of CPSIA – as additional documentation and labeling requirements also apply.
The CPSIA general requirements for children’s products include:
- Compliance with relevant standards
- CPSIA Children’s Product Certificate (CPC): A Practical Guide
- Tracking label
- Warnings (when applicable)
- Test report
The UN (United Nations) and DOT (Department of Transportation) issues recommendations for the transport of dangerous goods worldwide. The UN 38.3 is a regulation concerning the safe packaging, shipment, and documentation requirements for the transportation of lithium batteries, including button and coin batteries.
Examples of batteries covered by UN 38.3 include:
- Lithium metal batteries
- Lithium-ion batteries
UN 38.3‘s shipping standards include:
- UN 3090: Lithium metal batteries
- UN 3480: Lithium-ion batteries
- UN 3091: Lithium metal batteries contained, or packed with equipment
- UN 3481: Lithium-ion batteries contained, or packed with equipment
The process of demonstrating compliance with 38.3 include the following:
a. Conducting required tests (i.e. T1-T8) and obtaining qualified test reports by industry-recognized testing companies
b. Having the applicable shipping paper/Declarations for Dangerous Goods (if applicable)
c. Aviation safety appraisal (if applicable)
Freight forwarders might also require a Safety Data Sheet (SDS).
UN 38.3 also specifies the packaging requirements for lithium batteries, including:
- Packaging methods
- Label information on the packaging
- Standard that packaging should conform to (drop test)
- Package weight
Senate Bill 3278
Senate Bill 3278 was introduced in late 2021 to promulgate consumer product safety standards. This bill requires certain consumer products, including batteries, to use child-resistant closures and warning labels.
The intention of this bill, which is under review at the time we are writing this article, is to protect children and other consumers from the hazards of ingesting button cells or coin batteries.
The bill proposes that button cell and coin batteries should be packaged in accordance with the requirements of the 16 CFR Part 1700.15 – Poison Prevention Packaging Standards.
This means that the packaging for such products should be tested to determine whether the packaging is difficult enough for children to open.
The bill proposes that button cell and coin batteries must include a warning label on the product, packaging, or the user manual. The warning information should:
a. Explain the ingestion hazard clearly
b. Instruct consumers to keep new and used batteries out of the reach of children
c. Instruct consumers to seek immediate medical attention after ingesting the batteries
The requirements promulgated under this bill do not apply to any toy products that are in compliance with ASTM F963 standard.
In order to confirm product compliance, you test your products against applicable standards. Examples of tests that apply to button and coin battery include:
- Short-circuit test
- Crush test
- Impact test
Here we list some lab testing companies that offer lab testing services to manufacturers and importers of batteries:
- TÜV SÜD