On August 14, 2024, the U.S. Consumer Product Safety Commission (CPSC) issued a notice of proposed rulemaking (NPR) through the WTO, G/TBT/N/USA/2137, aiming to strengthen the safety requirements for toy products containing button batteries or coin batteries. The following are the main contents of the new regulations and their recommendations to related companies.

I. Main contents of the proposed rule

1. Performance and labeling requirements

To reduce or eliminate the risk of injury and death to children 6 years old and younger from accidentally ingesting or inhaling button batteries or coin batteries, the proposed rule requires strengthening safety standards in the design and labeling of toy products. The specific requirements are as follows:

? All toy products containing button or coin cells must comply with the performance and labeling requirements of the ASTM F963 toy safety standard referenced in 16 CFR 1250.
?These requirements include ensuring that battery compartment covers have safety guards to prevent children from accidentally opening them, and clear label warnings to alert parents to the potential dangers of button batteries.

2. Consistency requirements

The requirements will be consistent with the latest rules under the Reese Act and international standards for electric toys to ensure that products meet the same safety standards in both the U.S. and global markets.

3. Revision of notification list

It is proposed to revise the CPSC's list of Notifications of Requests (NORs) to include toys containing button or coin cells, ensuring that these products are adequately tested and verified for safety before being placed on the market.

II. Customs reminders and industry responses

According to statistics from the U.S. Consumer Product Safety Commission (CPSC), there have been six recalls of toy products containing button batteries or coin batteries in the U.S. market from January 1, 2011 to March 19, 2024. The proposed rule is intended to provide a higher level of child safety protection.
Enterprise response strategy

1. Understand regulatory changes

Electronic toy companies should keep abreast of changes in the proposed rules, especially the publication and implementation date of the final rule of the notice, to ensure that product design, manufacturing and sales comply with the latest safety standards.

2. Perform performance testing

In response to the performance requirements of the new regulations, companies should conduct detailed performance tests on existing and future toy products containing button batteries or coin batteries as soon as possible. The tests should ensure that the battery compartment cover of the product has a protective function and test its anti-tampering performance in all possible scenarios.

3. Adjust and optimize product labels

According to the new regulations, companies need to check and update product labels to ensure that they clearly indicate potential hazards and safety warnings. It is recommended that label designs should highlight safety warnings and comply with 16 CFR 1250 and ASTM F963 standards.

4. Pay attention to compliance inspections and recall notifications

Companies need to closely follow compliance inspections and recall notices issued by the CPSC, learn from the compliance experience or mistakes of other products to avoid similar risks. At the same time, they need to establish communication channels with consumers to facilitate timely handling of potential problems and complaints.

5. Cooperation with testing agencies

Companies can choose to cooperate with third-party testing agencies with certification qualifications to conduct regular product compliance testing and certification to ensure that products always comply with the latest regulatory requirements.

Conclusion

The CPSC's Notice of Proposed Rules (NPR) reflects the increasing attention and strict control of child safety protection in the US market. Electronic toy companies should pay close attention to regulatory changes and make adequate preparations to ensure that product design and labeling meet new safety standards to reduce potential risks and compliance costs.