TIANQIUUS button battery packaging law: Reese’s Law, 16 CFR 1263 and UL 4200A
If you import button cell or coin cell batteries into the United States, the packaging has to be child-resistant and carry specified warnings. We are the OEM factory: the cell is our product, the brand and the packaging specification are yours. Here is what the rule asks for, and exactly what we supply.
What does Reese’s Law require for button cell batteries?
Reese’s Law (Public Law 117-171) was signed in August 2022 after a child died from swallowing a button cell. It requires child-resistant packaging for button and coin cell batteries sold separately, and safe battery compartments plus warning labels for products that contain them. The CPSC implements it through 16 CFR Part 1263, which adopts ANSI/UL 4200A-2023 as the mandatory safety standard.
| Element | What it means in practice |
|---|---|
| Child-resistant packaging | Batteries sold on their own must be supplied in packaging that resists opening by young children, verified by a performance test |
| Warning label | The packaging must carry the specified hazard warning and symbol, at font sizes set by the size of the Principal Display Panel |
| Legal basis | Reese’s Law (P.L. 117-171), codified as 16 CFR Part 1263 |
| Technical standard | ANSI/UL 4200A-2023, incorporated by reference by the CPSC final rule of 21 September 2023 |
| In force | From 19 March 2024 |
| Applies to | Consumer products containing, or designed to use, button cell or coin cell batteries sold in the United States |
Who is responsible for US packaging compliance in an OEM order?
This is what OEM means: the cell is ours — designed, tooled and manufactured in our plant. The brand on it and the packaging specification are yours. Under US rules the packaging obligation follows the party placing the product on the market, so the pack design and its test sit with you, and the cell specification sits with us.
| You specify (brand owner / importer) | We deliver (OEM factory) |
|---|---|
| Your brand, your model naming, your market | The cell: chemistry, dimensions, capacity, tooling |
| The packaging design and its child-resistance test report | Printing and packing to your approved dieline and artwork |
| The warning text, symbol and required languages | Reproduction at the font sizes you specify |
| The decision to place the product on the US market | The cell-level and transport documentation that travels with the shipment |
What is ANSI/UL 4200A-2023, and what does it test?
ANSI/UL 4200A-2023 is the safety standard the CPSC adopted as mandatory, covering products that incorporate button or coin cells. It sets out performance tests for the battery enclosure and for separate battery packaging, plus detailed warning and labelling requirements — including font height tied to the size of the packaging’s Principal Display Panel.
| Area | What the standard addresses |
|---|---|
| Battery enclosure | Compartments holding replaceable cells must require a tool or at least two independent movements to open |
| Packaging performance | Child-resistance testing of the pack itself, including compression and stress-relief checks and a battery replacement test |
| Warning & labelling | Required hazard wording and symbols, with font heights derived from the Principal Display Panel size |
| Instructions | Warning content that must also appear in the instruction sheet or user manual |
Which of our cells fall under this rule?
A button cell or coin cell is defined as a single cell with a diameter greater than its height. That covers essentially every small round cell we make for consumer use — the CR lithium coin series, the AG alkaline button series and the SR silver-oxide watch cells. If a cell is sold on its own to US consumers, its packaging is in scope.
Cells built into a device and not intended for consumer replacement are handled under the enclosure requirements instead of the packaging requirements. Tell us how the cell reaches the buyer and we will tell you which side of the rule applies. Full model-level data is on the button cell range and each model page.
What we supply as the cell manufacturer
We make the cells, print them and pack them into the retail format you approve, from our own plant. For a US-bound button cell programme that means producing to your tested packaging design rather than to a generic pack, and keeping the printing, pack count and artwork under your sign-off at every proof stage.
| We provide | Detail |
|---|---|
| Cells | Mercury-free alkaline, lithium coin and silver-oxide button cells to the agreed specification |
| Printing | Your brand and model on the cell jacket, plus required marking such as voltage and 0% Hg |
| Packaging | Tooling, printing and packing to the child-resistant format you supply, in blister, card or box as your dieline requires |
| Proofing | Artwork proofs and pack samples for your sign-off before the production run |
| Shipping data | UN38.3 transport documentation and MSDS for lithium cells; MSDS and the transport declaration for alkaline cells |
| Traceability | Production date coding and batch records for the run |
Cell-level certificates and test references are listed on battery certifications. For the European market, see the EU 2023/1542 compliance notes. The packaging questions buyers raise before a PO are collected in the battery FAQ, and the freight and declaration side is in our shipping policy.
What we need from you to pack compliantly
Send these five items and we can quote, tool and produce a US-bound button cell programme without a second round of questions. If you have not settled the packaging design yet, say so in the enquiry — we will tell you what the pack format has to do before it can be tested.
1. Tested pack design
A reference sample or the design that has passed your ANSI/UL 4200A-2023 test
2. Warning artwork
The warning text and hazard symbol required for your Principal Display Panel
3. Languages
Which languages your market requires on the card or insert
4. Pack count
Cells per pack and packs per carton, plus pallet rules if you have them
5. Volume
The quantity you plan to run, so we can confirm tooling and lead time
What do buyers ask about US button battery packaging?
Does Reese's Law apply to batteries sold on their own, not inside a device?
Who arranges the UL 4200A test — the factory or the importer?
Can you print the US warning label and hazard symbol on my packaging?
Does this apply to CR2032 coin cells as well as AG4 and AG6?
Our packaging is already printed. Can it be made child-resistant?
What do you need from us before you can pack to a compliant design?
This page summarises the US requirement for sourcing purposes and is not legal advice. Confirm the position for your own product with your compliance team or a qualified adviser.
How do I start a US-bound button cell programme?
Send the cell model, the pack format and your target market, and we return a specification, a packaging plan and a landed-cost quote — usually within one working day.