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Last reviewed: September 2026 · Copy link

Button cell toys compliance

Products using coin or button cell batteries must meet 16 CFR Part 1263 performance and labeling (Reese’s Law) in addition to toy testing when marketed to children. Screw-secured or tool-required compartments, pass/fail torque tests, and warning labels are common failure points on light-up toys, talking books, and cheap novelty items.
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CPC citation stackDesign before PO
Generate CPC with battery rules

CPC citation stack

  • 16 CFR Part 1252 / ASTM F963 as applicable.
  • 16 CFR Part 1263 for button/coin cell accessibility.
  • CPSIA lead and phthalates on housings.
  • Tracking labels per Section 103.

Design before PO

Specify secured battery doors with the factory before tooling. Retrofit clips after mold opening is expensive and still may fail torque tests.

Questions people ask

Do AAA batteries trigger Part 1263?

Part 1263 targets coin/button cells — other formats follow F963 battery clauses. Confirm cell type on the BOM.

Are replacements sold separately regulated?

Replacement battery packaging has labeling rules; do not ship loose coin cells inside toy boxes without compliance review.

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