Microsoft Word - ITI Comments CPSC NPR Button Batteries Info Collection_CPSC Docket 2023_0004_4August2026

Status: Original and derived artifacts are available for this document.

Download: pdf

Before the Consumer Product Safety Commission
Bethesda, MD 20814

In the Matter of
Agency Information Collection
Activities; Extension of Collection;
Comment Request; Safety Standard for
Button Cell or Coin Batteries and
Consumer Products Containing Such
Batteries

)
)
)
)
)
)
)
)
)
)
)

CPSC Docket No. 2023–0004

COMMENTS OF THE INFORMATION TECHNOLOGY INDUSTRY COUNCIL (ITI)
The Information Technology Industry Council (ITI)1 welcomes the opportunity to provide comments on
the above-mentioned proceeding.
The Commission significantly underestimated burden and did not reflect real-world complexity, such as
lifecycle documentation (not one-time effort), global model and packaging complexity, and crossfunctional coordination. Under the Safety Standard for Button Cell or Coin Batteries and Consumer
Products Containing Such Batteries, all consumer products containing coin/button are burdened with
additional markings which are not required in all cases for ICT under the international product safety
standard, as summarized in the following table:

UL 62368-1 instructional safeguard requirements
Conditional based on exposure risk and allow
simplified markings when space is limited, with the
complete warning text in the accompanying
documentation.
Do not always require color on product markings. In
many cases product markings are molded or etched
into the enclosure surface.
Align with international marking schemes (including
ISO/IEC symbols) that are commonly used with ICT
equipment are commercially available (off-the-shelf
labels) or can be easily incorporated into print-ondemand labeling on the production line.

1

16 CFR part 1263 requirements
Require warnings across multiple physical touchpoints,
including packaging, product marking where
applicable/practical, and accompanying
instructions/manuals; online materials can supplement
but do not replace required physical warnings.
Require prescriptive warning labels with specific text,
symbols, display locations, and minimum text-height
requirements based on the applicable display surface
area.
Result in custom labeling which not only impact
supply chain costs but also could force manufacturers
to make product design changes (e.g. going from etch
or molded to physical labeling).

The Information Technology Industry Council (ITI) is the premier global advocate for technology, representing the
world’s most innovative companies. Founded in 1916, ITI is an international trade association with a team of
professionals on four continents. We promote public policies and industry standards that advance competition and
innovation worldwide. Our diverse membership and expert staff provide policymakers the broadest perspective and
thought leadership from technology, hardware, software, services, and related industries.

Additionally, the required content of the general certification of conformity (GCC) does not align with
European Union (EU) and United Kingdom (UK) Declaration of Conformity (DoC) content that is
commonly applicable to ICT products incorporating coin/button cells. Therefore, the requirements
mandate a completely new form or substantial modifications to a manufacturer’s DoC to support US, EU
and UK compliance. The burden calculations should be adjusted to reflect global manufacturers’ realistic
implementation experience with the requirements.
The labeling requirements of the standard are causing challenges, especially with global packaging
harmonization. For example, labeling changes required for size, font, color, and text specific
requirements for both product and packaging require more than one hour to ensure artwork is accurate
and the label fits on the product surface. The time estimate should take into consideration the time to
create the artwork and document all relevant size/font/color requirements. Due to the complexity of the
label requirements, complying with the requirements easily takes at least three to four hours per label or
more, excluding any other design changes needed to affix the label or hang tags or roll out the changes
to all the impacted SKUs bill of materials. These hours can include artwork creation, regulatory review,
font/size/color verification, translations, packaging fit checks, document control, SKU/BOM updates,
supplier release, and implementation tracking.
The Commission can address these challenges by:
•

Allowing for minimal warnings where appropriate, such as placement of the battery warning icon
only on the packaging with the full warning in the manual and/or online.

•

Allowing the use of electronic labelling (e.g., QR code), leading to online manuals on the
manufacturer’s website.

Finally, ITI requests clarification on the scope of the standard. The phrase “products designed to use”
should be clarified to consider the construction and intended use of the coin cell battery itself, specifically,
how “designed to use” applies to products with embedded, inaccessible, non-user-replaceable coin cell
batteries; service/replacement parts; and products where the battery is incidental to memory/backup
functions. Clearer scope guidance would avoid unnecessary documentation burdens for lower-risk
products and help manufacturers focus compliance resources on products that present meaningful
consumer exposure risk.

Respectfully submitted,
Information Technology Industry Council (ITI)
By:

/s/ Stephanie Barrett
Stephanie Barrett
Senior Director of Policy, Product Regulatory
Information Technology Industry Council
700 K Street NW, Suite 600
Washington, D.C. 20001