CPSC 16 CFR Part 1263 In-Depth Guide: Reese’s Law Button Battery Safety Standards and Cross-Border E-Commerce Compliance

Abstract: 16 CFR Part 1263 is a mandatory safety standard for button/coin batteries and consumer products containing such batteries, promulgated by the CPSC on September 21, 2023 (88 FR 65295) following the passage of Reese’s Law (Pub. L. 117-171, 15 U.S.C. 2056e) by the U.S. Congress. The regulation establishes a comprehensive child ingestion prevention system across three dimensions: battery compartment design, warning labels, and packaging identification. Product compliance requirements took effect on October 23, 2023, while battery packaging label requirements took effect on September 21, 2024. Cross-border e-commerce sellers of any products containing button batteries (remote controls, electronic toys, calculators, car key fobs, LED lights, etc.) must ensure compliance.

I. Reese’s Law Legislative Background

Reese’s Law is named after Reese Hamsmith, an 18-month-old girl from Texas who tragically died after ingesting a button battery from a remote control. When a button battery is swallowed by a child, the battery generates an electrical current upon contact with saliva or gastric acid, which can cause severe chemical burns to the esophagus or gastrointestinal tract within as little as 2 hours, leading to internal bleeding, organ perforation, and even death.

According to CPSC statistics, approximately 3,500 cases of button battery ingestion-related emergency room visits occur annually in the United States, with the vast majority of victims being children under 6 years old. In August 2022, U.S. President Joe Biden signed Reese’s Law, requiring the CPSC to develop button battery safety standards.

According to § 1263.1(a), the regulation’s purpose is to “eliminate or adequately reduce the risk of injury and death from ingestion of button/coin batteries by children 6 years of age and younger.”

II. Core Regulatory Requirements

2.1 Scope of Covered Products (§ 1263.1)

This regulation applies to any consumer product containing button batteries or coin batteries. Common affected products include:

• Remote controls (TV, air conditioner, garage door, etc.)
• Electronic toys and gaming devices
• Calculators
• Car keys / key fobs
• LED lights / decorative lights
• Electronic scales / kitchen scales
• Thermometers / blood glucose meters and other medical devices
• Greeting cards (with music playback function)
• Electronic candles
• Smart tags / luggage trackers

2.2 Battery Compartment Safety Requirements (Performance Requirements)

The regulation imposes strict requirements on the battery compartment design of products containing button batteries: the battery compartment must require a tool (such as a screwdriver) or at least two independent and simultaneous hand movements to open. This means:

• Battery compartment covers must be secured with screws (requiring a screwdriver to open), or
• Two independent actions requiring simultaneous use of both hands (e.g., press + slide) to open;
• Simple press-to-open battery compartments are no longer compliant.

This requirement must be satisfied under reasonably foreseeable use and misuse scenarios — the CPSC will consider various ways children might interact with the product.

2.3 Warning Label Requirements (§ 1263.3 and § 1263.4)

(a) Product Packaging Labels (§ 1263.4)

Packaging of consumer products containing button batteries must include prominent warning labels clearly alerting to the ingestion hazards of button batteries. Labels must include:

• Warning symbol;
• “WARNING: This product contains button or coin batteries” or similar language;
• Ingestion hazard description and first aid instructions;
• Instructions to store batteries out of reach of children.

(b) On-Product Labels

The product itself (or near its battery compartment) must bear a permanent warning label alerting consumers to the battery hazard.

(c) Instruction Manual Labels

Enclosed instruction manuals must contain comprehensive button battery safety warnings and usage instructions.

(d) Standalone Button Battery Packaging Labels

Retail packaging for button batteries sold separately must also bear complete warning labels (this requirement applies to battery packaging manufactured or imported after September 21, 2024).

2.4 Exemption Provisions (§ 1263.1(c)(d))

Toy Exemption: Toy products that already comply with the battery accessibility and labeling requirements of 16 CFR Part 1250 (ASTM F963 Toy Safety Standard) may be exempt from Part 1263 requirements.

Specific Battery Type Exemption: The CPSC has determined that zinc-air button/coin batteries do not pose ingestion hazards and are therefore not subject to Part 1263. Zinc-air batteries are typically used in devices such as hearing aids.

III. Effective Date Timeline

• October 23, 2023: Performance requirements (§ 1263.3) and product/instruction manual labeling requirements for consumer products containing button batteries take effect;
• September 21, 2024: Retail packaging labeling requirements for button batteries (§ 1263.4) take effect (applicable to battery packaging manufactured or imported after this date).

IV. Impact on Cross-Border E-Commerce Sellers

1. Product Design Modification Needs

Many existing products containing button batteries require design modifications:

• Converting simple press-type battery covers to screw-secured types;
• Or designing battery compartment mechanisms requiring simultaneous two-hand operation to open;
• This may necessitate new tooling and increased manufacturing costs.

2. Packaging and Labeling Upgrades

All product packaging requires redesign to include warning labels, and both on-product labels and instruction manuals need updating.

3. Inventory Clearance Risks

After October 23, 2023, products containing button batteries that do not comply with Part 1263 may not be sold in the U.S. market. Sellers must promptly clear old inventory or cease shipments to the U.S.

4. Certification Requirements

• General consumer products: Must issue GCC, based on a reasonable testing program declaring compliance with Part 1263;
• Children’s products: Must issue CPC, tested by a CPSC-accepted laboratory;
• If the product is simultaneously a toy (qualifying for the Part 1250 exemption), follow the toy certification pathway.

V. Five-Step Compliance Implementation

Step 1: Product Inventory

List all SKUs containing button/coin batteries, noting battery type (confirm whether zinc-air), and battery compartment design type (screw/snap/press, etc.).

Step 2: Design Evaluation and Modification

For battery compartment designs that fail to meet safety requirements, communicate with factories for design changes. Refer to the battery compartment accessibility requirements in ANSI/UL 4200A-2023 as design guidance.

Step 3: Labeling Design

Based on CPSC warning label templates, update the following items:

• Product packaging outer box labels;
• Product body permanent labels;
• Product instruction manual safety sections.

Step 4: Testing and Certification

Commission a CPSC-accepted laboratory for battery compartment safety testing, and upon obtaining test reports, issue GCC or CPC certificates.

Step 5: Ongoing Monitoring

Note the transition period for battery packaging label requirements (September 21, 2024) and ensure subsequently procured battery packaging is compliant.

VI. E-Commerce Platform Compliance Developments

Since 2023, Amazon has required sellers of products containing button batteries to submit compliance documentation, including:

• Test reports from ISO 17025-accredited laboratories (based on ANSI/UL 4200A or 16 CFR Part 1263);
• GCC certificate;
• Product packaging and label photographs.

Certain categories (such as remote controls and car key fobs) have been designated as “mandatory compliance” products by Amazon; failure to submit documentation will result in listing restrictions.

---

Further Reading

• 16 CFR Part 1303: Lead Paint Ban and Children’s Product Compliance
• 16 CFR Part 1262: Magnet Product Safety Standards Explained
• 16 CFR Part 1203: Bicycle Helmet Safety Standards Explained

📋 Need CPSC Compliance Consultation?
If the products you sell contain button batteries and you are uncertain whether they meet Reese’s Law/16 CFR Part 1263 requirements, please contact our compliance team. We provide one-stop services for battery compartment design evaluation, testing certification, and labeling compliance.