Reese’s Law for Importers: Button Battery Products and 16 CFR 1263

Reese’s Law, codified at 15 U.S.C. 2056e and implemented in 16 CFR part 1263, reaches far beyond battery importers. It applies to any consumer product that contains or is designed to use a button or coin cell battery, even when the batteries are sold separately. For an importer of electronics, home goods, lighting or gifts, every SKU with a button or coin cell in it, or a compartment built for one, carries a certificate obligation that sits outside the product’s usual compliance checklist.

Since July 8, 2026, the data from that certificate also has to reach ACE at entry through the CPSC PGA Message Set. This piece covers the scope of the rule, its performance and labeling requirements, the two exclusions that matter at import, and how the certificate is filed. The wider CPSC import framework is in our CPSC compliance guide.

Scope: Every Product That Contains or Uses a Button or Coin Cell

The trigger in Reese’s Law is the battery, not the product category. A consumer product is in scope if it contains a button or coin cell or is designed to use one. A product shipped without its cell is still designed to use one, so it is still covered. The practical consequence is that scope has to be determined from the bill of materials and the product specification, not from the HTS code or the product name.

Two groups sit outside the product requirements: toys that comply with the battery provisions of 16 CFR 1250, and products using zinc-air cells. Both are covered below. Everything else that is a consumer product and uses a button or coin cell needs a certificate citing 16 CFR 1263.

The certificate type follows the intended user. A general-use product is certified on a General Certificate of Conformity (GCC). A children’s product that falls under Reese’s Law, and is not a toy covered by 16 CFR 1250, is certified on a Children’s Product Certificate with third-party testing. Reese’s Law appears on both of CPSC’s certificate lists for that reason.

Performance and Labeling Requirements Under 16 CFR 1263

The rule has two operative sections. 16 CFR 1263.3 sets performance and labeling requirements for consumer products containing button or coin cells by incorporating UL 4200A-2023. Testing to that standard is what supports the citation on the certificate, and the test report is the evidence the certifier must be able to produce.

16 CFR 1263.4 sets warning label requirements for the packaging of button and coin cell batteries themselves, for packages made or imported after September 21, 2024. Loose batteries also fall under the child-resistant packaging requirement of section 3 of Reese’s Law (Pub. L. 117-171; 16 CFR 1700.15). A battery importer therefore certifies the packaging and labels on a GCC citing 1263.4, separate from any product certificate.

For a GCC, the testing can come from any qualified lab, and first-party testing is acceptable, based on a test of each product or a reasonable testing program. That flexibility helps large electronics importers whose suppliers already run in-house test programs, but the certificate still has to name every lab or party whose testing it relies on, with name, address, email and phone, and the most recent test date.

Component testing is allowed under 16 CFR part 1109. A GCC for a finished product can rely on a test of the battery compartment assembly supplied by a component vendor, provided due care and traceability are maintained. Component certificates are voluntary and are never eFiled, but the component testing has to be recorded on the finished product certificate.

The Toy Exclusion and Zinc-Air Cells

Toys that comply with the battery provisions of 16 CFR 1250, the rule that incorporates ASTM F963, are exempt from the Reese’s Law product requirements. That does not mean the toy needs no certificate. It means the battery obligation is certified through the toy standard instead: the Children’s Product Certificate lists the applicable ASTM F963 sections, cited individually by section number, and 1263 is not the rule relied on.

The boundary between a toy and a children’s product that is not a toy decides which rule applies, and both land on a CPC. A children’s product that is not a toy and contains a coin cell is certified to 1263. A toy powered by a coin cell that complies with the 1250 battery provisions is certified to F963. Getting that boundary wrong produces a certificate that cites the wrong rule for the battery hazard, which is a substantive error, not a formatting one.

Zinc-air cells are excluded from the rule. A product that uses only zinc-air cells has no 1263 obligation. If the same product line also has a variant using another button cell chemistry, that variant is in scope, and the one-product-per-certificate rule means the two variants need separate treatment.

Certificate and eFiling for Coin-Cell Products

The certificate carries the seven data elements required by 16 CFR 1110.11: product identification, each applicable rule listed separately, certifier, records custodian, date and place of manufacture, the most recent date and place of testing with each lab relied on, and the attestation. A product that is also subject to other CPSC rules lists those too. A painted adult furniture item with an integrated coin-cell light, for example, would cite both 1303 and 1263.

At entry, the importer files either the Full PGA Message Set, with all certificate data mapped to CATAIR v2.5 records, or the Reference PGA Message Set, which transmits the Certifier ID, Product ID and Version ID of a certificate already certified in CPSC’s Product Registry. CPSC’s burden estimate puts a Reference filing at 15.3 seconds against 4.75 minutes for a Full filing (90 FR 1800), which makes loading certificates into the Registry once and referencing them per line the practical route for high-volume electronics catalogs. Our CPSC eFiling support handles that Registry onboarding and transmits the set with each entry.

A certificate covers one product. A change in design, manufacturing process or location, or component, paint or material source makes the product materially different and requires a separate certificate. For coin-cell products, a redesigned battery compartment or a move to a new factory are examples of that trigger.

At CPSC’s request, the U.S. International Trade Commission created additional HTS codes for products containing button or coin cells (90 FR 1800, Response 30), and Reese’s Law products are a category on CPSC’s 1USG review list. A flagged line returns an Under Review status while CPSC evaluates it, with a clock of 4 business hours for air and truck and 8 for ocean, longer where risk factors are added. Correct HTS classification therefore determines not only duty but whether a line draws CPSC review at all. Where the classification is contested, a binding ruling fixes the tariff number before the eFiling logic is built on it.

Mapping Coin Cells Across a Large Catalog

CPSC flagged the core difficulty in its own rulemaking: retailers and large importers do not always know which SKUs contain coin cells (90 FR 1800, Response 30). A catalog of household goods can include a few hundred battery-powered items spread across headings that mostly hold unpowered goods. The HTS code is not a reliable proxy.

The control that works is a SKU attribute set captured at product onboarding, before the first purchase order:

• Battery present or designed to use: none, button or coin cell, zinc-air only, other chemistry.
• Product type for scope: toy under 16 CFR 1250, other children’s product, general-use product.
• Certificate method at entry: Reference (with Certifier ID, Product ID and Version ID), Full, or Disclaim A for cell-free units under a flagged HTS code.
• Test basis: lab name and contact, test date, and whether a component test on the battery compartment is relied on.
• Factory and manufacture month, so a change of plant triggers a new certificate.

Cell-free products under the same HTS code

Where a product that uses no button or coin cell is classified under a code CPSC flags for Reese’s Law screening, the importer can file Disclaim A with an intended use code. The disclaim is optional, but CPSC encourages it because it explains why no certificate accompanies the line and reduces the possibility of a hold. A disclaim on a product that does contain a coin cell is a false statement, so the SKU attribute has to be verified, not assumed.

Keeping these attributes in a trade compliance management system, next to HTS and origin, lets the broker’s software select the right CPSC method on each line without a manual check.

Enforcement Exposure for Missing or Wrong Coin-Cell Data

ACE does not reject entries for missing CPSC data. CSMS #69382435 (July 29, 2026) tells software developers to let filers submit even when CPSC flagging requirements are not met, and CPSC has said it does not currently intend to ask CBP to deny entry solely for failure to eFile. That is not a safe harbor. CPSC may respond with an SO message reviewing or rejecting the data, and missing or false data raises the risk score and the likelihood of an exam.

The legal exposure is the same as for any certificate rule. Goods not accompanied by a required certificate, or accompanied by a false one, can be refused admission under 15 U.S.C. 2066(a)(2). Refused goods are destroyed unless export is approved and completed within 90 days, with all costs on the owner or consignee and unpaid costs becoming a lien on future imports. Failure to furnish a certificate is a prohibited act under 15 U.S.C. 2068(a)(6), with civil penalty maxima of $120,000 per violation and $17,150,000 for a related series (86 FR 68244). CPSC is due to recalculate those maxima on December 1, 2026; the new amounts have not been published.

A licensed customs brokerage team can check certificate data against the invoice and product master before transmission, and our customs compliance platform keeps certificate identifiers alongside entry lines. The certificate content itself remains the importer’s responsibility under 16 CFR 1110.15. Duty on the batteries as goods is a separate question, covered in our note on EV and battery tariffs.

Frequently Asked Questions