What must you collect before advertising a button-battery gadget?

01

What battery and product identity should you record?

Create an identity record detailed enough to distinguish the inspected unit from similar-looking supplier stock.

Record the battery designation, chemistry, voltage, quantity, and manufacturer. State whether each battery is installed, packaged separately, or supplied by the customer. Classify access as consumer-replaceable, service-replaceable, or non-replaceable.

Record the gadget’s model, SKU, version, colorway, lot or date code, manufacturing date, and factory where available. Photograph the battery, closed and open compartment, fasteners, product labels, manual, and every side of the retail package. Products designed to use covered batteries may fall within the rule even when no battery is supplied, according to 16 CFR Part 1263.

1. Compare the sample identity with the purchase order and invoice.
2. Ask the supplier to confirm the identifiers on current production units.
3. Stop if answers differ between the sample, report, and sellable inventory.

02

What must the battery compartment show?

Inspect the real unit and document exactly how the battery becomes accessible.

For a replaceable battery, confirm that opening requires a coin, screwdriver, or other tool, or at least two independent and simultaneous hand movements that cannot be combined into one movement with one finger. Fasteners and covers are also subject to construction and secureness provisions, and the compartment must remain secure following applicable use-and-abuse testing. The rule’s construction and testing basis is explained in the CPSC business guidance.

Photograph the compartment closed, each opening action, the loosened fastener, and the removed battery. For a non-replaceable battery, collect evidence showing whether the enclosure prevents access after testing or the battery is secured by soldering, rivets, equivalent fasteners, or another tested method. A “non-replaceable” description alone is not physical evidence.

1. Check whether ordinary household tools can expose a service-only battery.
2. Confirm the sample’s screw, cover, latch, and internal retention match the report photographs.
3. Do not film until unexplained access or construction differences are resolved.

03

Which warnings must you collect?

Collect readable evidence from every required warning location, not just a warning copied into a supplier PDF.

Request photographs or scans of the overall retail package, the product warning, the area visible during battery installation or access, every battery-related instruction page, and any separately packaged battery. CPSC guidance addresses ingestion-hazard warnings on packaging, products, and instructions, with placement depending on the product and whether direct labeling is practicable.

Instructions should address keeping new and used batteries away from children, seeking immediate medical attention after suspected ingestion, completely securing the compartment, and stopping use and keeping the product away from children if the compartment cannot close securely. Review the current CPSC button-battery guidance rather than rewriting warning language from memory.

1. Check legibility, contrast, permanence, language, and placement on the production unit.
2. Compare the warning artwork with the tested and certified version.
3. Reject mock-ups that do not represent the package customers will receive.

04

What if the battery is packaged separately?

Treat a separately packaged battery as its own packaging-evidence checkpoint.

Button or coin batteries sold separately, or packaged separately with a consumer product, generally require special packaging meeting applicable Poison Prevention Packaging Act requirements. CPSC describes this packaging as child-resistant and senior-friendly and addresses the relevant child and adult testing in its button-battery FAQs.

Collect sealed-package photographs, package specifications, manufacturer identity, child-resistant and adult-use test records, and evidence tying the tested packaging to the shipped package. Also collect the applicable warning artwork and package dimensions. Current warning visibility, prominence, legibility, permanence, contrast, and sizing requirements appear in 16 CFR 1263.4. A loose battery inside a shipping carton is not evidence that these requirements were met.

05

Which test report should you request?

Request the complete applicable report for the exact model—not only a declaration, certificate, or one-page pass summary.

For a product within scope, verify coverage of ANSI/UL 4200A-2023 through 16 CFR 1263.3. Depending on the product and construction, the report may address thermal preconditioning, simulated battery replacements, drops, impact, crush, compression, torque, tension, final accessibility probing, and non-removable-battery secureness. The Federal Register rule explains the incorporated performance requirements.

Check the report’s model number, photographs, dimensions, materials, compartment design, fasteners, battery configuration, product classification, test dates, and laboratory. Children’s products generally require testing by a CPSC-accepted third-party laboratory; general-use certification may rely on testing by another competent laboratory under the applicable certification framework.

1. Compare report photographs side by side with the sample.
2. Ask whether components, tooling, factories, or manufacturing processes have changed since testing.
3. Escalate missing pages, model families without a clear rationale, or unexplained construction differences.

06

Which certificate must accompany the records?

Determine whether the gadget is a general-use product or a children’s product, then collect the corresponding certificate.

A general-use product subject to a consumer product safety rule requires a General Certificate of Conformity. A children’s product requires a Children’s Product Certificate. For imported products manufactured overseas, CPSC identifies the importer as responsible for issuing the applicable certificate; a foreign supplier’s document does not automatically discharge that responsibility. See the CPSC certification guidance.

Check for specific product identification, applicable regulatory citations, certifier and manufacturer information, manufacturing date and location, test date and laboratory, and a records contact. Where relevant, verify citations covering product performance, warnings, and separately packaged batteries. The certificate, report, sample, invoice, and intended inventory should describe the same product.

07

What footage and claims should remain blocked?

Do not publish creative that contradicts the approved construction, instructions, or evidence.

Block footage showing tool-free one-motion access, removal or loss of a required fastener, a loose battery near a child, food, mouth, or pet, unattended replacement, customer replacement of a non-replaceable battery, continued use with a damaged compartment, or a sample different from sellable inventory. Demonstrate only the handling permitted by the instructions and supported by the inspected product.

Avoid claims such as “childproof,” “completely safe,” “certified,” or “fully compliant” unless the exact communicated meaning is supported. The FTC states that advertisers need a reasonable basis for objective express and implied claims before dissemination. A test report supports only what it actually tested; review the FTC advertising-substantiation policy.

ATIYO can preserve the approved sample identity, supplier evidence, brief, assets, iterations, and reusable creative learnings in one operating record. It does not verify legal compliance or replace product-safety counsel. Media performance remains in the ad platform, while ATIYO preserves creative context and learnings.

1. Mark the project “hold” until every evidence field has an owner and accepted record.
2. Convert approved handling restrictions into explicit filming instructions.
3. Run the edited asset against the physical product, warnings, manual, and approved claims before launch.