button cell or coin batteries & dangerous good classification confusion
Hello,
As we prepare to launch our upcoming product, I am conducting research on the classification of dangerous goods and would appreciate your guidance on a few points.
I noticed that some products that has LED operated tealight candles are not classified as dangerous goods, while some of them are. I also understand that these products likely contain coin or button-cell batteries, which are regulated under Reese’s Law. I would be grateful if you could help clarify the following:
1. Are products containing coin or button-cell batteries automatically classified as dangerous goods, or does the battery type (alkaline vs. lithium) affect this classification?
2. I have come across references to an "exemption sheet" for battery-powered products, which I find somewhat confusing. Are these exemption sheets used to avoid classification as dangerous goods? If we use alkaline-based button-cell batteries instead of lithium-based ones, would our product still be considered a dangerous good?
3. If our product is classified as a dangerous good and we are not currently eligible to sell such products, what steps should we take? If we provide the necessary documentation, would we be permitted to sell, or is there a mandatory waiting period for eligibility?
We are asking these questions to ensure we are fully prepared for the process and can gather all necessary documentation in advance.
I appreciate your time and assistance, and I look forward to your response.
button cell or coin batteries & dangerous good classification confusion
Hello,
As we prepare to launch our upcoming product, I am conducting research on the classification of dangerous goods and would appreciate your guidance on a few points.
I noticed that some products that has LED operated tealight candles are not classified as dangerous goods, while some of them are. I also understand that these products likely contain coin or button-cell batteries, which are regulated under Reese’s Law. I would be grateful if you could help clarify the following:
1. Are products containing coin or button-cell batteries automatically classified as dangerous goods, or does the battery type (alkaline vs. lithium) affect this classification?
2. I have come across references to an "exemption sheet" for battery-powered products, which I find somewhat confusing. Are these exemption sheets used to avoid classification as dangerous goods? If we use alkaline-based button-cell batteries instead of lithium-based ones, would our product still be considered a dangerous good?
3. If our product is classified as a dangerous good and we are not currently eligible to sell such products, what steps should we take? If we provide the necessary documentation, would we be permitted to sell, or is there a mandatory waiting period for eligibility?
We are asking these questions to ensure we are fully prepared for the process and can gather all necessary documentation in advance.
I appreciate your time and assistance, and I look forward to your response.
4 replies
Seller_i6S8knzW6zU6Z
Hi @Seller_02sRLH0gmHdHQ,
Regarding battery types and dangerous goods classification:
Under "Button cell and coin batteries covered by this policy" (help page), Amazon distinguishes between:
- Button batteries (using alkaline, silver oxide, or zinc air; 1-5 volts)
- Coin batteries (using lithium; 3 volts)
About the exemption sheets:
You can indeed use them for battery-powered devices. The help page (see here) specifically lists "Batteries and battery-powered devices" as one of two cases where exemption sheets are accepted. However, this is just for documentation - you'll still need to meet all safety requirements.
For selling these products, here's what you'll need according to the "Required information" section (help page):
- Product model number displayed on your detail page
- Safety instructions and user manuals
- General Certificate of Conformity showing UL 4200A compliance
- Testing results from an ISO 17025-approved lab
- Product images showing compliance with packaging and labeling requirements
Once you submit everything correctly, the review typically takes about 2 business days. The process is outlined in the "Review time" section here: help page.
Hope this helps clarify things!
Best regards, Michael
Manny_Amazon
Hello @Seller_02sRLH0gmHdHQ,
On top of what @Seller_i6S8knzW6zU6Zmentioned (thank you for this valuable info), feel free to review the article I've written regarding button or coin cell batteries which covers what the requirements are for listing products with these type of batteries - 💭Thinking About Selling...Products With Batteries
Regards,
- Manny