Button Battery Mandatory Standards for Amazon Australia Sellers: The Four Standards Explained

Four mandatory standards cover button and coin batteries in Australia, and all four apply to you if you list a product on Amazon.com.au that contains one, or sell the batteries themselves. They are a safety standard and an information standard for products containing batteries, and a safety standard and an information standard for the batteries. They commenced on 22 December 2020 and the requirements apply from 22 June 2022. This is general information, not legal advice; confirm with the ACCC or a compliance consultant.

What are the four button battery standards?

The explanatory statements describe the set as one package: consumer goods containing button/coin batteries, plus the batteries themselves. The standards define button and coin batteries as flat, round single-cell batteries up to 32 mm in diameter and 1 to 11 mm high.

Does my product count as "containing" a button battery?

Probably, if it uses, is powered by or is intended to operate with one. The scope includes goods designed to store batteries, such as containers and organisers, and accessories such as remote controls.

Common Amazon examples are remote controls, digital kitchen scales, LED tea lights, light-up toys, greeting cards with sound, car key fob covers, bathroom thermometers and fitness trackers. Ask yourself whether a child could get a battery out.

Exemptions are narrow. The safety standard does not apply to goods first supplied to a consumer before the application day, one-off sales by a person who acquired the goods as a consumer, hearing aids, trade-only equipment not for the public, and soldered-in batteries in audio-visual or IT equipment and office machines. Second-hand goods supplied by a business are not exempt.

What does the safety standard for products require?

Three construction rules apply to goods containing button or coin batteries:

1. The compartment holding the batteries must be resistant to being opened by young children.
2. The batteries must not release during reasonably foreseeable use or misuse.
3. Fasteners for compartment doors or covers must be captive.

Suppliers must perform compliance tests to show the standard is met, and must nominate the tests they relied on if a regulator asks. The tests can come from product-specific industry standards or from a general standard for products containing button batteries. The standard applies whether or not the battery is meant to be replaced.

Testing is not something an Amazon listing can fix. Ask your manufacturer for the test reports and have an accredited laboratory check them. Blooprint does not do product testing or certification.

What are the packaging rules for the batteries themselves?

The packaging of an "applicable" battery must resist opening by young children. Applicable means lithium cells wider than they are tall, or non-lithium cells 16 mm or more in diameter and wider than tall.

• Blister packs of applicable batteries must release only one battery at a time.
• Spare batteries supplied with a product, where the battery is not pre-installed in a secure compartment, must be enclosed in child-resistant packaging.
• The packaging standard does not apply to zinc-air hearing aid batteries, bulk trade supply not for the public, or batteries already installed in goods.

If you sell loose batteries on Amazon, splitting multipacks into your own bags or bundles changes the packaging you supply, and the packaging standard looks at the packaging of the batteries as supplied. Check before you do it. See Amazon FBA prep and labelling in Australia before you split multipacks.

What warnings must appear and where?

Battery packaging must carry a warning with an alert word, safety alert and "keep out of reach of children" symbols, a statement that the battery is hazardous, medical-attention advice and, for lithium cells, a statement that it can cause severe or fatal injury in 2 hours or less if swallowed. Lithium button or coin batteries 20 mm or more in diameter must carry a "keep out of reach of children" symbol on the cell, at least 6 mm in diameter.

For products, the information standard requires a warning in the accompanying instructions, a warning on the front panel of packaging (at minimum symbol warnings), and a warning attached to unpackaged goods, such as a swing tag or sticker. Lower-risk goods, such as hearing aids, fully enclosed batteries, batteries not intended to be replaced by a consumer and batteries installed by a specialist, need a warning in the instructions only, or attached to the goods if there are none.

What should my Amazon.com.au listing say?

The information standards recommend, but do not require, that goods and batteries supplied through an electronic platform include a warning in the product description that is clearly visible, prominent and legible. They also recommend Poisons Information Centre contact details and safe disposal advice.

A sensible listing includes:

• A bullet point stating the product contains a button or coin battery and is not a toy, where true.
• A line that the battery compartment is secured with a screw, if it is.
• Clear photos of the pack front panel showing the warning symbols.
• The warning text you use on the pack, repeated in the description.

Amazon's policy for hazardous products and electronics sits inside Seller Central. Read it alongside this page. For wording and upload mechanics, see Amazon listing optimisation in Australia.

How do I audit my existing Amazon catalogue for button batteries?

Work through it in this order. It takes an afternoon for a catalogue of a few hundred ASINs.

1. Export your inventory from Seller Central and search titles, bullets and descriptions for words such as remote, key, fob, light-up, LED, scale, thermometer, tracker, musical, greeting card and watch. Many products that contain batteries never say so in the title.
2. Open the manual or the product for every hit and note the battery type, for example CR2032 or LR44. A "CR" code usually means lithium; the standard turns on chemistry and diameter, so confirm the cell rather than guess.
3. Sort into three groups: battery sold separately, battery installed with a screwed or locked compartment, and battery loose in the box.
4. For each group, collect evidence: test reports for the compartment, photos of the warnings on the front panel and in the instructions, and your supplier's confirmation of the battery brand and its packaging.
5. Fix or delist. Where evidence is missing, stop selling until it is in hand. A listing is quick to rebuild; a regulator notice is not.

Remember that spare batteries supplied in the box, where the battery is not pre-installed in a secure compartment, must be enclosed in child-resistant packaging. That one catches many remote-control and key-fob sellers who add a loose spare battery as a bonus.

What does the standard not tell me?

The standards are lengthy, and parts of the compliance tests refer to industry standards that must be purchased. The explanatory statements note that referenced technical standards can be bought from SAI Global or ISO, and that the ACCC can make a copy available for viewing at one of its offices. Whether a particular product passes depends on those test standards, which this guide does not reproduce. Ask an accredited laboratory or a compliance consultant, and confirm with the ACCC if your product is borderline.

Amazon does not publish a public button-battery-specific document checklist for Amazon.com.au. Amazon publishes its hazardous-products and electronics policies inside Seller Central.

FAQ

When did the button battery standards become mandatory? They commenced on 22 December 2020 with an 18-month transition, so the requirements apply from 22 June 2022. Stock supplied after that date must comply.

Do the standards apply to products I import in bulk before I list them? They apply when you supply goods in Australia. Check stock before shipping to FBA, because non-compliant units cannot be fixed once inbound. See importer of record on Amazon Australia.

Which batteries need child-resistant packaging? Lithium cells wider than tall, and non-lithium cells 16 mm or more in diameter and wider than tall.

Is a screwed battery door enough? A captive-fastener door helps, but the standard also requires the compartment to resist opening by young children and requires compliance testing.

Are hearing aids covered? Hearing aids are excluded from the product safety standard, and zinc-air hearing aid batteries are excluded from the packaging standard.

What if I find a non-compliant product after listing it? Stop selling and take advice. Breaches of safety standards carry large penalties (see product safety on Amazon Australia), and a death or serious injury must be reported within 2 days.

Next steps

Start from the Australia hub, check which of your ASINs contain batteries, and gather test reports and pack photos. For help rewriting listings with compliant warning text once the product is compliant, see Amazon listing management in Australia. Blooprint is an Amazon SPN verified partner working with Australian sellers remotely from Bengaluru.