The U.S. Consumer Product Safety Commission (CPSC) has established warning label requirements for the packaging of button cell or coin batteries, as well as consumer products containing such batteries, that go into effect on September 21.

The rule – called Reese’s Law – was enacted in 2022 and enforces federal safety guidelines for button cell or coin batteries and products containing these batteries to prevent ingestion by small children.

  • Toy products for children under 14 compliant with the Toy Standard and zinc-air button cell or coin batteries are exempt from these requirements.


This is the newest component of Reese’s Law to go into effect after performance guidelines for these products were enacted on March 19. These regulations include requiring a tool to open the battery compartment of consumer products, and performance tests each product must pass to be deemed safe.

  • A child swallowing these batteries is a life-threatening medical emergency, according to the CPSC. These batteries can burn through the throat and esophagus of a child within two hours following ingestion.


“The mandatory standard requirements consistent with Reese’s Law help companies in the consumer product landscape, especially in the promotional products industry, to mitigate legal risks and avoid potential liability,” says Sanjay Kotia, MAS, manager of product compliance and quality assurance at SnugZ USA – the No. 7 supplier in the PPAI 100. “Non-compliance could lead to recalls, lawsuits or damage to the organization’s brand reputation.”

Warning Label Requirements

All button cell or coin battery packaging and accompanying manuals, whether sold individually or with a consumer product, must include warning labels that adhere to specific guidelines.

  • All warning statements must be in English, clearly visible, permanent and follow minimum size standards.


Packaging must have a warning label on the principal display panel, typically on the front of packaging, that’s most likely to be displayed. This panel must display safety statements addressing the following:

  • Inform consumers of the hazards of ingesting button cells or coin batteries.
  • Advise consumers to keep new or used batteries out of reach of children.
  • Instruct consumers to seek immediate medical attention if a battery is ingested.


A warning label must also be present on the secondary display panel, opposite the principal display panel, and usually on the back or side of packaging. This label must include safety-related statements that address the following:

  • Inform consumers to keep batteries in original packaging until they’re ready to be used.
  • Advise consumers to immediately dispose of used batteries—somewhere other than in household trash—and keep the batteries away from children.
  • Instruct consumers to call local poison control centers for treatment if a battery is ingested.


“By taking these steps to make sure that products meet or exceed safety standards, promotional products companies can build consumer trust and enhance their brand image,” says Kotia, a member of PPAI’s Product Responsibility Action Group (PRAG). “Adhering to Reese’s Law isn’t just a regulatory necessity, but also a critical safety and business imperative.”

Product Responsibility Summit To Feature CPSC Chair

The CPSC has proposed a revision requiring all toys using button cell or coin batteries to meet performance and labeling requirements set by the agency, regardless of whether they follow the Toy Standard. This is because the CPSC found current standards don’t sufficiently reduce the risk of ingestion.

  • The deadline for interested or affected parties to submit comments is October 15.


If there is any confusion surrounding the CPSC’s proposal, the man in charge of the agency will be at PPAI’s Product Responsibility Summit.

Alexander Hoehn-Saric, chair of the Consumer Product Safety Commission (CPSC), will speak at Summit, which will take place September 22-24 in Alexandria, Virginia. Hoehn-Saric’s session will include a Q&A format. Attendees who have specific questions – including any concerning the proposal on button cell batteries – for the government official can send them to rick.brenner@productsafetyadvisors.com.

Anyone interested in attending PPAI’s Product Responsibility Summit can still register by clicking here.