Health Canada Issues Hazard Notice on Button / Coin Cell Batteries Under CCPSA: Immediate Enforcement Without Transition Period On September 18, 2026, Health Canada released a hazard notice formally incorporating consumer products containing button/coin batteries, as well as retail packaging for button/coin batteries, into the General Prohibitions framework of the Canada Consumer Product Safety Act (CCPSA). Effective immediately upon publication of the notice, non-compliant products may not be manufactured, imported, advertised or sold in Canada — no transition period is granted.

1. Scope of Control

Button/coin batteries are listed due to the risk of accidental ingestion. When lodged in the esophagus and exposed to bodily fluids, these batteries can generate an electric current, causing severe internal chemical burns or even death in as little as 2 hours. Between June 2011 and June 2025, Health Canada received 41 related incident reports, including 4 fatal cases.

Two categories are regulated:

• Consumer products containing button/coin batteries, covering lithium, alkaline and silver-oxide chemistries.
• Retail packaging for standalone button/coin batteries.

Products and packaging using zinc-air button/coin batteries are temporarily exempted. Officials explain that zinc-air batteries require exposure to air to generate electricity and are less likely to form an internal circuit inside the human body if swallowed.

Regulatory definition of button/coin cell: small single-cell battery where diameter > height, typically 5–30 mm in diameter and 1–11 mm in height. “Toys” refer to products intended for learning or play by children under 14 years old.

2. Compliance Benchmarks: Three Lines – Product, Packaging, Labelling

The General Prohibitions follow a compliance logic: meet one of the listed performance benchmarks or demonstrate equivalent safety; no single mandatory standard is designated. Requirements by regulated item are shown below:

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Two practical implementation notes:

• Warnings must be bilingual in English and French. Health Canada’s assessment document includes official English and French warning texts in appendices; equivalent wording is acceptable. US-only English labels cannot be directly used for the Canadian market.
• Primary product verification focuses on the battery compartment. Under above standards, the compartment generally requires a tool or coin, or two separate simultaneous manual actions to open. Additional requirements include securing screws, anti-disengagement design, normal-use and abuse testing.

3. Alignment & Differences with US Reese’s Law

For manufacturers serving both North American markets, impacts can be split into reusable and supplementary requirements:

• Reusable: Product performance benchmarks align between Canada and the US. ANSI/UL 4200A-2023 applies for non-toy products and ASTM F963 series for toys.
• Key differences: Canada specifies standards for packaging and labelling, while US requirements are mainly defined by statutory text. Canada mandates French warnings, which are not required on US labels. In addition, Canada does not currently require special packaging for zinc-air batteries.

4. Compliance Checklist for Exporters

1. Product inventory review: Map product models containing button/coin batteries and identify zinc-air battery products for exemption screening.
2. Mechanical structure verification: Confirm battery compartment meets requirements: tool/coin operation OR two separate simultaneous actions to open.
3. Packaging verification: For separately sold button/coin batteries, confirm child-resistant packaging matching applicable standards for reclosable / non-reclosable formats.
4. Label review: Verify complete bilingual English-French warnings on products, packaging and user manuals.
5. Document retention: Archive certificates of conformity, test reports and supplier declarations. Health Canada states outreach will be prioritized after the notice release but enforcement may occur at any time. Complete documentation is critical to demonstrate compliance during official inquiries.

Important reminder: CCPSA Section 7(a) binds manufacturers and importers; Section 8(a) covers all parties with a “knowledge” element. Distributors and retailers are also subject to regulation. Enforcement actions include seizure, mandatory corrective measures, product recalls, administrative monetary penalties (AMPs), and even criminal prosecution.

Official Sources

1. Health Canada's approach to the General Prohibitions under the CCPSA (Table 3: Determination of notice of danger to human health or safety, updated 2026-09-18)https://www.canada.ca/en/health-canada/services/consumer-product-safety/legislation-guidelines/guidelines-policies/information-regulated-parties-enforcement-approach-general-prohibitions.html
2. Health Canada hazard assessment for products containing button/coin batteries and their packaging (includes performance benchmarks, applicable clauses and bilingual warning texts)https://www.canada.ca/en/services/health/consultations/consultation-comment-period-danger-human-health-safety-assessment-products-containing-button-coin-batteries-packaging/document.html
3. Canada Consumer Product Safety Act (CCPSA), Sections 7(a) and 8(a)https://laws-lois.justice.gc.ca/eng/acts/c-1.68/
4. Health Canada public consultation on hazard assessment (Nov 24, 2025 – Jan 22, 2026)https://www.canada.ca/en/services/health/consultations/consultation-comment-period-danger-human-health-safety-assessment-products-containing-button-coin-batteries-packaging.html

Disclaimer: This article is compiled from public Health Canada information for reference only and does not constitute legal advice. All requirements are subject to the official Health Canada publications and the full text of referenced standards.