Why Is the CPSC Renewing Paperwork Rules for Button Batteries Now?

What the notice actually does

The document published on October 5, 2026 is not a new safety rule. It is a routine paperwork renewal under the Paperwork Reduction Act. CPSC submitted a request to OMB to extend control number 3041-0195, which covers the recordkeeping and labeling documentation that manufacturers and importers must maintain under 16 CFR part 1263. That regulation implements Reese's Law, 15 U.S.C. 2056e(a) and (b). The standard itself — child-resistant compartments, warning labels on packaging, warnings in manuals, and on-product warnings where practicable — stays exactly as written.

How the burden numbers changed

CPSC estimates 15,363 entities respond each year. Each entity responds three times annually. The agency now calculates two hours for labeling and two hours for recordkeeping per response. That totals 184,356 hours per year (4 hours × 3 × 15,363 = 184,356). At $48.97 per hour from the December 2025 Bureau of Labor Statistics employer-cost survey, the annualized cost reaches approximately $9 million (184,356 hours × $48.97 = $9,027,913.32).

The previous estimate used 1.25 hours for each task. Two commenters — the Information Technology Industry Council and an anonymous filer — argued real-world compliance takes three to four hours per label. CPSC agreed to raise the figure to two hours each, noting that response times vary by firm size, product count, and internal practices. The agency also noted labeling is not typically redesigned every year, so a two-hour annual average is reasonable.

What manufacturers still have to do

Reese's Law requires warnings in three places: on battery packaging, on product packaging that contains the batteries, and in any accompanying literature. Where practicable, warnings must also appear on the product itself. UL 4200A-2023, incorporated by reference in 16 CFR 1263.3, and CPSC's own requirements at 16 CFR 1263.4 both provide letter-size tables scaled to display area. Smaller surfaces get smaller letters. Alternative display methods are allowed when the full warning does not fit.

Electronic labeling does not replace physical warnings. CPSC acknowledged QR codes could supplement the information but said not all consumers have internet access or the skill to scan codes. The rule does not forbid high-contrast monochrome printing; color is required only when labels use more than one color.

Where the comment period fits

Comments on the collection itself are due by November 4, 2026. They go to OMB at OIRA_submission@omb.eop.gov or by fax to 202-395-3888. A copy should also be submitted electronically at regulations.gov under Docket No. CPSC-2023-0004. Three comments were received on the earlier June notice: one from the People's Republic of China under the WTO/TBT Agreement, and the two that drove the burden increase. The docket already holds 44 supporting documents, including meeting logs from UL TC4200 and correspondence from DASMA, WCMA, and Harman.

The renewal does not change the safety standard. It only keeps the paperwork authority alive. If OMB does not act before October 31, the collection authority lapses — but the underlying regulation at 16 CFR part 1263 remains enforceable.