In September 2023 the US Consumer Product Safety Commission voted to approve UL 4200A-2023 as a mandatory consumer product safety rule for consumer products containing button cells, in order to reduce the ingestion hazard to children aged six and under.

UL 4200A was first published in February 2015 and has been revised five times. Before the CPSC rule, many end product standards already stated that products containing button cells must meet UL 4200A, including UL 1082, UL 982, UL 1026, UL 1081 and UL 507. The CPSC rule further widens the mandatory application of UL 4200A: any product containing a button cell must meet its requirements.

1. Construction

Where the end product has a battery that the user may remove or replace, the construction must meet the following requirements.

1. Test probe 11 of IEC 61032 must not be able to touch the battery. Enclosures that can be opened without a tool, or by hand with fewer than two independent consecutive actions, must be opened during the examination for assessment.

2. The product must be designed to prevent children from removing the battery:

The battery compartment must require a tool such as a screwdriver or coin to open, with a minimum rotation of 0.5 Nm and 90 degrees, or the fastener must engage at least two full threads; or, if opened by hand, the lid or door of the battery compartment must require at least two independent and simultaneous actions.

3. If the battery compartment lid or door is secured by screws or similar fasteners, the fasteners must be captive to the lid or door, for example captive screws.

Where the product has a battery that the user is not intended to remove or replace, it must be effectively protected against removal by the user or a child, and the product must be designed so that:

1. The battery cannot be accessed through the enclosure or by similar means; or

2. The battery is fully secured by welding, rivets or similar means.

2. Test requirements

Torque testing, tension testing and compression testing have been added.

3. Product warning requirements

If there is insufficient space on the product surface, the symbols below may be used, but their meaning must be explained in the user manual or other printed material supplied with the product.

4. Packaging warning requirements

Where packaging space is sufficient, use Figure 7B.1 or Figure 7B.2.

Where packaging space is insufficient, use Figure 7B.3 or Figure 7B.4.

5. Packaging warning wording

Use the standard wording corresponding to the applicable case.