Why is the CPSC renewing paperwork rules for button batteries?

The Consumer Product Safety Commission has asked the Office of Management and Budget to extend approval for data collection tied to button cell and coin battery safety rules. The current approval expires on October 31, 2026, and the renewal would keep reporting requirements in place for manufacturers and importers.

The notice is about paperwork, not the standard itself

The document published on October 5, 2026, does not change the safety standard. It announces that CPSC submitted a renewal request for OMB control number 3041-0195. The Paperwork Reduction Act requires this step every few years. The earlier notice appeared on June 15, 2026. Three public comments arrived before this filing.

Who files and how often

CPSC estimates 15,363 entities will respond each year. Those entities are manufacturers and importers of battery packages plus manufacturers and importers of non‑children's products that contain or are designed to use button or coin batteries. Each entity responds three times per year on average. The agency assumes two hours for labeling work and two hours for recordkeeping per response. That yields 184,356 total hours annually.

The cost calculation

The hourly rate comes from the Bureau of Labor Statistics: $48.97 for private industry workers in goods‑producing industries, December 2025 data. Multiply 184,356 hours by that rate and the annualized cost reaches $9,027,913.32. The notice cites the BLS archive page directly. It adds up.

Comments pushed the burden estimate up

ITI argued the real burden runs three to four hours per label, not the earlier 1.25 hours. The anonymous commenter echoed that view and asked for electronic labeling options, clearer scope guidance, and streamlined recordkeeping. CPSC agreed to raise the estimate to two hours for labeling and two for recordkeeping. The agency noted labeling is not redesigned every year, so two hours per year is reasonable. On electronic labels, CPSC said the rule requires physical warnings but does not forbid adding digital access.

What the standard actually requires

Reese's Law, 15 U.S.C. 2056e(a) and (b), drives the rule at 16 CFR part 1263. Performance and labeling rules target child‑resistant compartments on products that use these batteries. Warning labels must appear on battery packaging, on product packaging, in accompanying literature, and on the product itself where practicable. UL 4200A‑2023 is incorporated by reference. The rule includes a letter‑size table based on display area and allows alternative warning formats when space is tight. High‑contrast monochrome printing is not prohibited; color is required only if the label uses more than one color.

What the notice does not say

The filing does not report how many batteries or products are currently on the market. It does not describe injury trends since the standard took effect. It does not say whether CPSC plans to revise the technical requirements themselves. The comment period closes November 4, 2026. After that, OMB decides whether to extend approval.