Button Cell & Coin Battery Injuries: Corporate Duties, Federal Safety Standards, and Accountability
By Adam J. Langino, Esq.
Button Cell & Coin Battery Injuries: Corporate Duties, Federal Safety Standards, and Accountability
Button cell and coin batteries power everyday consumer products—from remote controls and key fobs to small electronics and household devices. When these batteries become accessible to young children, the consequences can be catastrophic. The U.S. Consumer Product Safety Commission (CPSC) warns that swallowing a button cell or coin battery can be "immediate, devastating and deadly," and that a battery can burn through a child’s throat or esophagus in as little as two hours if swallowed.
This is a product-safety issue first and foremost. Corporations control product design, battery-compartment construction, testing, warnings, packaging, quality systems, and compliance decisions. Those choices determine whether batteries remain secured during real-world use—or become loose, liberated, and reachable by children. Federal law now makes clear that companies must engineer and verify safety against foreseeable use and misuse, not simply rely on consumer behavior.
The Hazard Is Severe and Predictable—So Prevention Must Be Engineered In
The CPSC explains that button cell and coin batteries are associated with thousands of emergency department visits every year, and that the consequences of swallowing a battery can be immediate and deadly.
The Federal Register rule likewise recognizes a consistent hazard pattern: children access batteries from consumer products either directly from the battery compartment or because batteries escape from the compartment.
Because the hazard is known, repeated, and severe, prevention must be built into product design. A predictable hazard calls for predictable corporate controls: secure compartments, robust construction, performance validation, and clear warnings as required by law.
Reese’s Law and the Mandatory UL 4200A Standard: A Federal Baseline for Corporate Conduct
Reese’s Law was enacted to protect children six years old and younger against hazards associated with ingestion of button cell or coin batteries. The CPSC adopted ANSI/UL 4200A–2023 as the mandatory safety standard for consumer products containing button cell or coin batteries, and incorporated that standard into federal regulations.
The scope of the rule is broad. Reese’s Law defines covered products as consumer products "containing or designed to use" one or more button cell or coin batteries, regardless of whether the batteries are intended to be replaced by the consumer or included with the product or sold separately.
The purpose is explicit: establish performance and labeling requirements to prevent child access to batteries during reasonably foreseeable use and misuse and to eliminate or adequately reduce the risk of injury and death to children six years old and younger.
What Corporations Must Do: Engineering Controls That Prevent Child Access
Secure battery compartments so they cannot be opened casually
Under the adopted standard, battery compartments for replaceable button cell or coin batteries must be secured so that they require either (1) a tool (such as a screwdriver or coin) or (2) at least two independent and simultaneous hand movements to open.
The Federal Register notice describes the performance framework behind that requirement: compartments must remain secure during reasonably foreseeable use and misuse conditions, with detailed evaluation of securement methods and locking mechanisms.
Prove safety through preconditioning and abuse testing
UL 4200A–2023 is not simply a design suggestion; it is a performance standard backed by testing expectations. The Federal Register notice describes requirements and testing concepts addressing foreseeable drops, impacts, and stresses that could cause a compartment to fail, open, or allow a battery to become accessible.
This matters because real-world products get dropped, bumped, pressed, pulled, and worn. A compliant design must remain secure over the life of the product—especially when the risk involves severe internal injury in a short period of time.
Address non-replaceable batteries too—because products still break
The Federal Register notice explains that Reese’s Law covers products containing button cell or coin batteries even when batteries are not intended for consumer replacement. The rule’s purpose includes preventing child access during foreseeable use and misuse, which includes scenarios where a product breaks or deteriorates and the battery becomes accessible.
Warnings and Labeling: Required—but Not a Substitute for Safe Design
Reese’s Law requires warning labels on (1) product packaging, (2) accompanying literature such as manuals, and (3) the consumer product itself where practicable. These warnings must clearly identify the ingestion hazard and include related instructions contemplated by the statute and implementing rule framework.
Warnings are important, but they are not enough on their own. The statutory and regulatory emphasis is on securing batteries through performance requirements so that the hazard is eliminated or adequately reduced during foreseeable use or misuse—not merely communicated after the product reaches consumers.
Compliance and Certification: Safety Must Be Documented
The Federal Register rule describes certification requirements under federal consumer product safety law for products subject to mandatory standards and explains that certain children’s products require third-party testing and certification.
Compliance is therefore not a matter of voluntary "best practices." It is an enforceable baseline requiring manufacturers and importers to align design, testing, labeling, and documentation with the mandatory standard.
Prevention Is Possible—and Corporations Control the Levers
The CPSC’s consumer education materials emphasize how quickly catastrophic harm can occur when a battery is swallowed, including severe injury in as little as two hours.
Reese’s Law and the CPSC’s implementing rule reflect a policy judgment that preventing child access must be driven by corporate action: secure compartments, validated performance under foreseeable misuse, and required warnings and labeling.
When corporations treat battery safety as an afterthought, families bear the risk. Product liability law exists to hold responsible parties accountable and to push safer design, testing, warnings, and compliance across consumer industries.
When Companies Fail: Product Liability and Accountability
Product liability claims can involve complex factual and technical questions and often require experience, investigation, and expert support. Langino Law’s Product Liability page explains that these cases may involve manufacturing defects, design defects, or failure to warn, and often require technical expert witnesses to explain how a product was unreasonably dangerous.
That page also explains that responsibility can extend across multiple parties in the distribution chain and may include manufacturers, designers, marketers, distributors, wholesalers, and—in some instances—retailers or sellers.
In button cell and coin battery injury cases, potential failures can include defective compartment design, inadequate securement, insufficient durability under foreseeable stress, or inadequate warnings where required—each of which can support different theories of liability depending on the facts.
Langino Law’s Product Liability page further notes that product recalls are not required for an injured person to file a lawsuit, and that recalls often follow litigation pressure that forces safety changes.
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1) CPSC Button Cell and Coin Battery Information Center: https://www.cpsc.gov/Safety-Education/Safety-Education-Centers/Button-Cell-Coin-Battery-Information-Center
2) Federal Register (CPSC Direct Final Rule; 88 FR 65274 / Doc. 2023–20333): https://www.federalregister.gov/documents/2023/09/21/2023-20333/safety-standard-for-button-cell-or-coin-batteries-and-consumer-products-containing-such-batteries
3) Langino Law Product Liability page: https://www.langinolaw.com/practice-areas/product-liability