HTSBase
CPSC general useUnited StatesButton battery products

Do products with button batteries need a GCC under Reese's Law?

Updated

Short answer

Yes. Children's products need a CPC instead.

Reese's Law led CPSC to adopt ANSI/UL 4200A-2023 as a mandatory rule in 16 CFR part 1263 for any consumer product that contains or is designed to use button cell or coin batteries, such as remotes, key fobs, kitchen scales, LED candles and greeting cards. The product needs a secured battery compartment, warnings on the product, package and manual, and a certificate: a GCC for general use products or a CPC for children's products. Loose batteries, including spares in the box, need child-resistant packaging.

What changes the answer

  • Which batteries. A button cell or coin battery is a single cell whose diameter is greater than its height (16 CFR 1263.2). Zinc-air cells, used in hearing aids, are excluded from part 1263 but still need child-resistant packaging.
  • Toys are covered elsewhere. Toys for children under 14 that meet the battery rules of the toy standard in 16 CFR 1250 are exempt from part 1263 under 1263.1(c).
  • Dates. CPSC's FAQ gives October 23, 2023 for general use products and December 20, 2023 for children's products, with enforcement discretion through March 19, 2024. Battery package warnings apply to packages made or imported after September 21, 2024.
  • Packaging for batteries. Section 3 of Reese's Law requires button and coin batteries, including those sold separately with a product, to be in special packaging meeting 16 CFR 1700.15, for batteries made or imported after February 12, 2023.

What to do

  1. Test the product to UL 4200A: battery compartment that needs a tool or two independent movements to open, abuse tests such as drop, impact, crush and torque, and the marking and warning requirements.
  2. Put the warnings on the product, the retail package and the instructions as UL 4200A and 1263 specify.
  3. Check that any batteries in the box are in child-resistant packaging that meets 16 CFR 1700.15 and carry the 1263.4 package warning.
  4. Issue a GCC citing part 1263 (and the PPPA packaging rule where batteries are included), based on a test or reasonable testing program, and eFile it with the entry. For children's products, third-party testing and a CPC apply.
HTS lines for button and coin cells
  • 8506.50.00.10

    8506: Primary cells and primary batteries; parts thereof

    Lithium / Button and coin cell batteries

    Lithium button and coin cells, such as CR2032.

    General rate
    2.7%
    Free or reduced under 17 programs
  • 8506.10.00.10

    8506: Primary cells and primary batteries; parts thereof

    Manganese dioxide / Button and coin cell batteries

    Alkaline manganese dioxide button and coin cells.

    General rate
    2.7%
    Free or reduced under 17 programs

Next steps

Frequently asked questions

Does a product with a soldered-in coin cell need to meet Reese's Law?
Part 1263 applies to products that contain button cell or coin batteries, regardless of whether they are meant to be replaced by the consumer. UL 4200A has provisions for batteries that are not accessible, so ask your lab how your design is assessed.
Does an LED candle with a CR2032 need a GCC?
Yes, as a general use product containing a coin battery. If it is marketed to children, it becomes a children's product, which means third-party testing and a CPC.
Does PPPA packaging testing need a third-party lab?
CPSC's FAQ says special packaging testing under the PPPA does not need a CPSC-accepted third-party lab. The certificate must still cite the packaging requirement.

Sources

  1. 16 CFR part 1263, Safety standard for button cell or coin batteries and consumer products containing such batteries, eCFR, National Archives
  2. 16 CFR 1263.1, Scope, effective date and exemptions, eCFR, National Archives
  3. Button Cell and Coin Battery FAQs (Reese's Law), U.S. Consumer Product Safety Commission
  4. 16 CFR 1700.15, Poison prevention packaging standards, eCFR, National Archives
  5. Certificates of Compliance final rule (eFiling), published January 8, 2025, Federal Register

This is general information drawn from the official sources linked above. It is not legal advice. Rules change and often turn on the facts of your product, so confirm your test plan with an accredited lab and your obligations with qualified counsel before you import or sell.