What the Warning on Button Battery Packs Actually Means

What is Reese’s Law?

Reese’s Law is the federal statute that told the Consumer Product Safety Commission to write this rule. The rule’s own first paragraph says so: “As required by Reese’s Law (15 U.S.C 2056e, Pub. L. 117-171), this part establishes performance and labeling requirements for consumer products containing button cell or coin batteries to prevent child access to batteries during reasonably foreseeable use and misuse of the consumer product.” The stated purpose is “to eliminate or adequately reduce the risk of injury and death to children 6 years old and younger from ingesting these batteries.” The rule is published in the Code of Federal Regulations at 16 CFR Part 1263, and every quotation in this post comes from that text.

The rule defines the hazard it is written against. An “ingestion hazard” is “a hazard caused by a person swallowing or inserting a button cell or coin battery into their body whereby” the battery “can become lodged in the digestive tract or airways” and “can potentially cause death or serious injury through choking, generation of hazardous chemicals, leaking of hazardous chemicals, electrical burns, pressure necrosis, or other means.” Those are the regulator’s words for why the rule exists, and this post does not restate them in its own.

What does the rule require of a product that uses these batteries?

One thing, by reference to a standard. “Each consumer product containing button cell or coin batteries shall comply with ANSI/UL 4200A, Standard for Safety for Products Incorporating Button Batteries or Coin Cell Batteries, approved on August 30, 2023.” The rule incorporates that standard by reference rather than reprinting it, so the standard’s own text is not in the regulation. The product requirement took effect October 23, 2023. A “consumer product containing button cell or coin batteries” is defined broadly: one “containing or designed to use one or more button cell or coin batteries, regardless of whether such batteries are intended to be replaced by the consumer or are included with the product or sold separately.”

One class of product is carved out. “Any object designed, manufactured, or marketed as a plaything for children under 14 years of age that is in compliance with the battery accessibility and labeling requirements of 16 CFR part 1250 is exempt from the requirements of this part.” A toy’s battery compartment answers to the toy standard, not to this rule.

What does the warning on a battery package have to say?

The rule sets the format before the words. All warning statements “must be clearly visible, prominent, legible, and permanently marked,” “in contrasting color to the background,” and “in English.” The signal word and safety alert symbol “must be in black letters on an orange background,” and the signal word “must appear in sans serif letters in upper case only.” Certain text in the message “must be in bold and in capital letters,” following the example labels the rule prints as figures.

Then the placement. The front of the pack, which the rule calls the principal display panel, “must include the warning label” shown in the rule’s figure 1, with an icon “at least 8 mm (0.3 inches) in diameter.” If there is no room for the full label, the icon goes on the front at “at least 20 mm in diameter” and the text goes on the back or side, the secondary display panel. The exact wording of the full warning lives in those figures, which eCFR renders as images, so this post quotes only the statements the rule sets out in text. Two of them must be “addressed on the principal display panel or secondary display panel”:

• “Keep in original package until ready to use.”
• “Immediately dispose of used batteries and keep away from children. Do NOT dispose of batteries in household trash.”

The second line is the one most readers have not seen before. The rule requires the package to tell you not to put a used coin battery in the household trash. It does not say where to put it instead, and neither does this post.

The packaging requirement has its own date: “Packages of button cell or coin batteries manufactured or imported after September 21, 2024, must meet the labeling requirements for battery packaging.” A pack made earlier can still be sold without the label. For batteries “packaged separately with a consumer product,” only the front-panel label and its small-package alternative apply, not the two trash and storage statements.

What the rule does not say

It does not rate one battery against another, name a brand, or say a product is safe. It sets a standard a product must meet and a label a package must carry. It does not cover AA, AAA, C or D cells, which are taller than they are wide and fall outside the definition’s first clause, unless the Commission determines that a battery “poses an ingestion hazard” under its second. It does not tell a household what to do with a used battery beyond keeping it out of the trash. And it does not reach a toy that already meets the toy standard’s battery rules.

Runlow holds no product records for batteries yet, so this post names no product. When records exist, each will carry what the brand’s own page says about the pack’s warning and its date of manufacture, in the brand’s words, with the date it was read. What “Made in the USA” on Pet Treats Actually Means covers another label claim a federal rule defines.

Where this comes from

Every statement above is quoted from one source, read on October 13, 2026: 16 CFR Part 1263, Safety Standard for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries, as published in the Code of Federal Regulations on eCFR. Runlow has not tested any battery or product and makes no claim about any of them. Nothing here is medical advice; the rule’s own words on the hazard are quoted above and this post adds none of its own.

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