Button cell or coin battery Compliance for product manufactured before Oct 2023
Hello Amazon.
My product has been flagged because it contains button cell batteries. I understand that Amazon has done this because of Reese's Law and the recent changes with 4200A. My manufacturer is in China and I have had an independent ISO 17025-approved lab evaluate product. They have concluded that it is not in compliance with 4200A (UL4200A). They identified the changes I need to make to be in compliance. Some are packaging notifications, others are minor product design changes. All will be incorporated in the next production run and submitted again for 4200A compliance before being sold on Amazon.
This was expected as my product was manufactured and received by Amazon via Amazon ocean freight services in October 2023. At the time of manufacturing 4200A did not apply. The effective date for 4200A is March 19, 2024.
I am hoping you can help me resolve this issue. I can provide documentation for the production run manufacturing dates and shipping. I can send you a link to the law citing March 19, 2024 as the effective date. I am hesitant to submit any of the independent labs evaluations because they make no reference to the effective date of 4200A.
I have submitted 2 appeals under Product Compliance Requests, in my Account Health, including references to the effective date of 4200A. Both were rejected.
Can you help before my product is suspended for sale by Amazon? What information can I provide to help you?
Thank you.
Button cell or coin battery Compliance for product manufactured before Oct 2023
Hello Amazon.
My product has been flagged because it contains button cell batteries. I understand that Amazon has done this because of Reese's Law and the recent changes with 4200A. My manufacturer is in China and I have had an independent ISO 17025-approved lab evaluate product. They have concluded that it is not in compliance with 4200A (UL4200A). They identified the changes I need to make to be in compliance. Some are packaging notifications, others are minor product design changes. All will be incorporated in the next production run and submitted again for 4200A compliance before being sold on Amazon.
This was expected as my product was manufactured and received by Amazon via Amazon ocean freight services in October 2023. At the time of manufacturing 4200A did not apply. The effective date for 4200A is March 19, 2024.
I am hoping you can help me resolve this issue. I can provide documentation for the production run manufacturing dates and shipping. I can send you a link to the law citing March 19, 2024 as the effective date. I am hesitant to submit any of the independent labs evaluations because they make no reference to the effective date of 4200A.
I have submitted 2 appeals under Product Compliance Requests, in my Account Health, including references to the effective date of 4200A. Both were rejected.
Can you help before my product is suspended for sale by Amazon? What information can I provide to help you?
Thank you.
11 replies
Atlas_Amazon
Hello @Seller_xKUZu9XKfnasv
"They have concluded that it is not in compliance with 4200A (UL4200A)."
Thank you for the information provided regarding the situation with your compliance request. I understand that your concern is regarding what information should be provided for review, and that the previously submitted information has been rejected.
For clarification, the product that you have is not in compliance because it was manufactured prior to the requirement? This would mean that the product cannot be sold on that platform as the effective date has passed. You would want to remove, and ship the product that is in compliance along with submitting the documents that support this.
If our team is unable to properly verify that your product and documentation meet all of the requirements, then they cannot accept and allow the product to be sold on the platform. We do encourage you to share any information or case details you have on this situation for additional review.
Best,
Atlas
