New challenges for export of household type products that incorporate or may use button batteries or coin cell batteries to the United States! New edition UL4200A:2023 interpretation

On August 16, 2022, the United States Congress enacted H.R.5313, also known as Reese's Law, to mandate federal safety testing for button or coin battery products. As required by Reese's Law, the U.S. Consumer Product Safety Commission (CPSC) has issued a Notice of Proposed Rulemaking (NPR) to regulate the safety of consumer products containing button/coin batteries.

On September 21, 2023, the CPSC issued a Direct Final Rule Document (188 FR 65274), Decided to adopt UL 4200A:2023 (Products Incorporating Button Batteries or Coin Cell Batteries, 2023-08-30) as a mandatory safety standard that consumer products containing button/coin batteries must meet, the relevant requirements are codified in 16 CFR part 1263.

The U.S. Consumer Product Safety Commission (CPSC) will grant a 180-day enforcement transition period from September 21, 2023 to March 19, 2024. The actual implementation date is March 19, 2024.

UL 4200A: 2023 standard analysis

Since its release in February 2015, UL 4200A has undergone five revisions. Prior to the CPSC's release of the requirements, many end-product standards already specified that products containing button batteries must meet UL 4200A requirements. These end product standards include UL 1082, UL 982, UL 1026, UL 1081, UL 507, etc. The specification issued by the CPSC further expands the mandatory use of UL 4200A. As long as the product contains a button battery, it needs to meet the requirements of UL 4200A.

UL 4200A:2015 Ed1+R30Aug2023 is the latest version to date, and its coverage has increased from the initial lithium battery to all battery types (except zinc-air batteries). UL 4200A systematically regulates button-containing battery products from multiple perspectives such as structure, testing, labeling, and specification. 

As follows：

1. New structural requirements are added, including that the battery compartment must be secured so that they require the use of a tool or at least two separate and simultaneous hand movements to open, and that these two opening movements cannot be accomplished by a finger combined in a single action.

2. Added torsion test, tensile test and compressive test.

3. product warning language requirements.

If the surface space of the product is insufficient, the following symbols can be used, but the meaning of the symbols should be explained in the product user manual or other printed materials packaged with the product:

4. product packaging warning language requirements.

As an alternative to Figure 7B.1, you can also use Figure 7B.2 instead:

5. Durability assessment requirements for warnings.

6. The instruction manual warning language requirements.

The above are only some of the key contents of the standard. For more details, please consult BTL engineers.