US Keeps Printed Coin Battery Warnings as CPSC Seeks Renewal

United States of America is extending information collection and requesting public comments on safety standards for button cell or coin batteries and consumer products containing such batteries, including battery-powered watches and clocks, as part of a broader regulatory review

The U.S. Consumer Product Safety Commission (CPSC), the federal product safety regulator, said on Oct. 5, 2026 that it had asked the Office of Management and Budget to renew the labeling and record-keeping rules for button cell and coin batteries and the products that use them, with public comments open until Nov. 4, 2026¹.

The current approval for these paperwork rules runs out on Oct. 31, 2026¹. The CPSC also raised its estimate of the work the rules cost businesses, and it turned down requests to replace printed warnings with QR codes¹.

In short, the warning labels and records needed to sell coin-battery goods in the United States stay in place. A shipment of loose coin batteries, or of goods that run on them, must still carry printed warnings on the box and in the manual.

What did the CPSC announce on Oct. 5?

The CPSC published a notice in the Federal Register under the Paperwork Reduction Act of 1995¹. This law requires agencies to get approval from the Office of Management and Budget (OMB) before they make businesses keep records or print information. The notice says the CPSC has now sent OMB a request to extend that approval¹.

The approval covers the Safety Standard for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries, found at 16 CFR part 1263¹. OMB tracks it under control number 3041-0195¹. The type of review is a renewal, so the rule itself does not change¹.

This is the second step of the renewal. On June 15, 2026, the CPSC published a first notice that it planned to seek the extension and asked for comments within 60 days². The CPSC received three comments on that first notice¹.

Which batteries and products does the coin battery rule cover?

The rule rests on Reese’s Law, a 2022 law meant to protect children six years old and younger from swallowing these batteries³. The law defines a button cell or coin battery as a single cell battery with a diameter greater than its height⁴. It also covers any other battery that the CPSC finds poses a swallowing hazard⁴.

The rule covers two kinds of goods¹:

• Packages of loose batteries, including coin batteries packed separately with a product.
• Consumer products that contain or use the batteries, for children and for adults alike.

The notice names the businesses that must keep the records. They are the manufacturers and importers of battery packages and of non-children’s products that contain or are designed to use these batteries¹. Children’s products are covered by the rule’s tests and labels too, though the notice lists non-children’s products for record-keeping¹.

What must coin battery goods carry at the U.S. border?

The rule sets two kinds of requirements¹. First, it sets performance tests for child-resistant battery compartments, which are battery doors that a small child cannot open. Second, it sets warning label rules.

Under Reese’s Law, the warnings must appear in several places³:

• on the packaging of button cell or coin batteries;
• on the packaging of products containing these batteries;
• in any literature that comes with the product, such as a user manual;
• where practicable, directly on the product, visible when the battery is put in or replaced.

The warnings must clearly name the swallowing hazard³. They must tell buyers to keep new and used batteries away from children and to get medical help at once if a child swallows one³.

How does the CPSC rule work for importers?

The CPSC first adopted the rule in a direct final rule, a rule that takes effect without a separate proposal stage, published Sept. 21, 2023³. That rule made a private standard, UL 4200A-2023, mandatory for products containing these batteries³. A separate rule set warning rules for battery packaging, because UL 4200A does not cover loose batteries³.

Products subject to the rule must be tested and certified as meeting it³. Products made or imported after Oct. 23, 2023 had to comply³. The CPSC gave a 180-day grace period for enforcement, from Sept. 21, 2023 to March 19, 2024, because testing labs were scarce³. Third-party lab testing of children’s products was not required before Dec. 20, 2023³.

The paperwork renewal now under review covers the labeling and record-keeping part of this work¹. It does not add new tests or labels.

How much work does the CPSC say the labels take?

The CPSC estimates that 15,363 businesses respond to the rule each year¹. Each responds about three times a year, the notice says¹.

In its June notice, the CPSC estimated 1.25 hours for labeling and 1.25 hours for record-keeping per response². That gave a total of 115,222.5 hours and about $5.6 million a year².

After the comments, the CPSC raised both figures to two hours each¹. The new total is 184,356 hours a year¹. At $48.97 an hour, the average pay of workers in goods-producing industries, the cost is about $9 million a year¹.

The CPSC said the time will vary by company size, by the number and type of products sold, and by internal practices¹. It added that labels are not usually redesigned every year, so two hours a year for labeling is reasonable¹.

Why did the CPSC reject QR code warnings?

The Information Technology Industry Council (ITI), an industry group, said the estimate was too low¹. It said each label takes at least three to four hours¹. ITI asked the CPSC to allow electronic labeling, such as a QR code linking to an online manual¹. An anonymous commenter made similar points about the time per label¹.

The CPSC said the rule does not stop companies from also offering the warnings online¹. But not all buyers have easy internet access or know how to use QR codes¹. For that reason, the warning text must come physically with the product¹.

For goods arriving at U.S. ports, a QR code alone will not meet the rule. The printed warning on the box and in the manual stays.

What about small packages and colour printing?

The anonymous commenter asked for other formats on small surfaces¹. The commenter also asked to allow high-contrast black-and-white printing on small retail packs¹.

The CPSC answered that both UL 4200A-2023 and its own rule at 16 CFR 1263.4 already contain a table of letter sizes based on the display area¹. Smaller letters are allowed on small surfaces¹. Both also offer other ways to show the warning when there is no room for the full text¹.

The CPSC also said the rule does not prohibit high-contrast monochrome printing, meaning black-and-white warnings¹.

China also sent a comment under Article 2.9.4 of the WTO agreement on technical barriers to trade¹. The CPSC treated it as outside the scope of this paperwork review, because it addressed the rule and the private standards themselves¹.

Is the UL 4200A standard about to change?

A separate review is under way. On Sept. 3, 2026, the CPSC said UL had told it of a revised standard, UL 4200A-2026⁴. The CPSC asked whether the revision improves safety, with comments due by Sept. 17, 2026⁴.

Reese’s Law sets a fixed process for this⁴. The CPSC may reject the revision, in whole or in part, by telling UL within 90 days of receiving notice that it does not improve safety⁴. If the CPSC does not act, the revised standard becomes the mandatory rule 180 days after the CPSC received the notice, or on a later date the CPSC sets⁴.

The September notice does not give the exact date UL notified the CPSC⁴. So the date the 2026 version could take effect is not yet fixed.

What happens next for the coin battery rules?

OMB will take comments on the paperwork renewal until Nov. 4, 2026¹. Comments go to OMB’s Office of Information and Regulatory Affairs and also to the CPSC docket, CPSC-2023-0004¹. The current approval expires on Oct. 31, 2026¹.

Meanwhile, the CPSC must decide on UL 4200A-2026 within the deadlines in Reese’s Law⁴. A change to the standard could change the tests and labels that coin-battery goods must meet.

Key points on the U.S. coin battery labeling rules

The table sums up the Oct. 5 notice and the related steps.

For now, nothing changes at the border: coin-battery goods still need child-resistant compartments, testing and printed warnings¹. The next date is Nov. 4, 2026, when OMB’s comment period closes¹.

Sources

1. ↩ Federal Register :: Agency Information Collection Activities; Extension of Collection; Safety Standard for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries https://www.federalregister.gov/documents/2026/10/05/2026-20347/agency-information-collection-activities-extension-of-collection-safety-standard-for-button-cell-or
2. ↩ Federal Register :: Agency Information Collection Activities; Extension of Collection; Comment Request; Safety Standard for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries https://www.federalregister.gov/documents/2026/06/15/2026-11912/agency-information-collection-activities-extension-of-collection-comment-request-safety-standard-for
3. ↩ Federal Register :: Safety Standard for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries https://www.federalregister.gov/documents/2023/09/21/2023-20333/safety-standard-for-button-cell-or-coin-batteries-and-consumer-products-containing-such-batteries
4. ↩ Federal Register :: Notice of Availability and Request for Comment: Revision to the Voluntary Standard for Products Containing Button Cell or Coin Batteries https://www.federalregister.gov/documents/2026/09/03/2026-18103/notice-of-availability-and-request-for-comment-revision-to-the-voluntary-standard-for-products