1. Background of Reese's Law & GCC Certification

In August 2022, the U.S. Reese's Law (P.L. 117-171) was officially signed into law, authorizing the CPSC (Consumer Product Safety Commission) to promulgate mandatory safety rules to systematically eliminate risks of chemical burns, tissue damage and even death faced by children from ingesting button cell batteries and coin batteries.

In September 2023, the CPSC issued a final rule in the Federal Register, incorporating ANSI/UL 4200A-2023 as a mandatory technical standard into 16 CFR Part 1263, requiring all manufacturers and importers to issue compliance certificates for consumer products containing button batteries:

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2. Applicable Product Scope & Exemptions

Reese's Law defines a button battery as any single-cell battery with a diameter greater than its height, mainly including CR/BR series lithium-manganese button batteries (such as CR2032, CR2016, etc.), as well as various silver oxide and alkaline button batteries. The following situations are exempt from the performance requirements of Section 2 of 16 CFR 1263:

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3. Core Technical Requirements of ANSI/UL 4200A-2023

3.1 Battery Compartment Protection Structure

• Replaceable batteries: Require screw fastening or dual-action (press + slide, at least two independent simultaneous hand movements) to open; fasteners shall be captive (non-detachable). • Non-replaceable batteries: Shall adopt welded, riveted or fully enclosed design, inaccessible via IEC 61032 test probe. • Mechanical test requirements: 4.5 kg tensile force for 10 seconds without loosening; 0.5 J impact without battery dislodgement; 2 N·m torque rotated 90° without opening.

3.2 Warning Labels (Three Mandatory Locations)

• Affixing locations: ① Product body (near battery compartment, if feasible); ② Principal display panel of retail outer packaging; ③ Accompanying user manual. • Label content (must include English warning text): "DANGER: Swallowing may cause chemical burns, tissue damage, and death. Keep out of reach of children." + ISO 7010 W001 warning symbol. • Durability: Shall not fall off or fade after alcohol wipe and friction test; minimum size of 7 mm × 9 mm. • Color: Only required to comply with specified color scheme for full-color printing; the blue "Keep Away" icon must be fully presented on complete labels, not required for split labels.

3.3 Ingestion-Resistant Packaging (Section 3 of Reese's Law)

• Individually sold button batteries shall use child-resistant packaging complying with 16 CFR § 1700.15 (PPPA - Poison Prevention Packaging Act standard). • Must pass both child test (80% of children under 5 cannot open within 5 minutes) and senior-friendly test (80% of adults over 70 can open within 5 minutes). • Batteries complying with ANSI C18.3M marking and packaging requirements are exempt from Section 3 special packaging requirements, but packaging labeling requirements (16 CFR § 1263.4) still apply.

4. GCC Certificate Requirements & eFiling

4.1 Essential Elements of GCC Certificate

Per CPSC requirements, the GCC certificate must include the following information:

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4.2 New eFiling Requirements Effective July 2026

Effective July 8, 2026, CPSC and CBP (U.S. Customs and Border Protection) will implement a new electronic filing (eFiling) regulation, requiring all imported consumer products under CPSC jurisdiction to submit electronic compliance certificate data via the Customs ACE (Automated Commercial Environment) system at clearance. For button battery products, enterprises must:

1. Complete GCC issuance before customs clearance, and pre-enter 7 core data items into the ACE system.
2. Ensure test reports cited in the GCC are fully consistent with data submitted to the system.
3. Amazon North America also requires test reports to be directly transmitted to the platform by laboratories via TIC (Testing, Inspection and Certification) channels; seller self-upload is not accepted.

5. Certification Process

1. Product Gap Analysis: Evaluate battery compartment structure, label placement and content against ANSI/UL 4200A-2023, and identify design defects requiring rectification.
2. Structural Rectification & Sample Preparation: Adjust battery compartment design (screw/dual-action) based on gap analysis; update product labels and packaging to ensure content, size and durability meet regulatory requirements.
3. Laboratory Testing: Send samples to a CPSC-accepted laboratory for full UL 4200A testing, including battery compartment mechanical tests (tensile/impact/torque), use and abuse tests, and label durability tests.
4. GCC Certificate Issuance: After obtaining the test report, the manufacturer or importer drafts and issues the GCC (or CPC) with correct regulatory clause citations, and retains records for no less than 5 years for inspection.
5. eFiling Data Preparation & Clearance: Enter key GCC data into the ACE system, and complete Amazon TIC submission simultaneously (if applicable) to ensure smooth customs clearance.

6. Key Timelines

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7. Non-Compliance Risks

• Cargo Detention: Cargo will be detained by CBP at port if eFiling data is missing or GCC information is incomplete. • Product Delisting & Recall: Mandatory delisting by Amazon or CPSC, with market-wide recall in severe cases. • High Civil Penalties: Maximum penalty of approximately $120,000 per violation, and up to $150,000 for intentional violations. • CPSC Key Monitoring List: Repeat violations will affect customs clearance of all subsequent products.

8. Closing Remarks

Button battery GCC certification is a mandatory compliance threshold for consumer products containing button batteries exported to the United States. With the full mandatory enforcement of UL 4200A in May 2026 and the implementation of the new eFiling rule on July 8, compliance requirements are further tightened. Enterprises should conduct product gap analysis as early as possible, complete structural rectification and laboratory testing, and ensure GCC certificates and eFiling data are ready simultaneously.

Guangdong Energy Storage Testing Technology Co., Ltd. provides UL 4200A testing and GCC certificate issuance services for button battery products, assisting enterprises in avoiding customs clearance and platform compliance risks, and achieving smooth market entry into the U.S.

Disclaimer

This article is compiled by Guangdong Energy Storage Testing Technology Co., Ltd. based on public regulatory information, for reference only. Specific certification requirements shall be subject to official CPSC releases, and this article does not constitute legally binding opinions. This article contains AI-assisted generated content and has no legal binding force.