Recently, many Amazon sellers have been frequently required by the platform to provide battery compliance documents when listing products such as button batteries, remote controls, electronic scales, LED light strings, and e-cards. Among these, the most common concern is: Is it necessary to conduct UN38.3 testing when selling button batteries?

Conclusion first: Not all button batteries require UN38.3 testing; only lithium-manganese button batteries such as CR2032, CR2025, CR2016, and CR2450 must undergo this test.

UN38.3 is the internationally recognized safety testing standard for lithium battery transportation. According to U.S. Federal Regulation 49 CFR 173.185, lithium metal and lithium-ion cells and batteries must comply with the requirements of Chapter 38.3 of the United Nations Manual of Tests and Criteria for the Transport of Dangerous Goods during shipping. Amazon also mandates that when listing lithium battery ASINs, sellers must upload a UN38.3 test summary, which serves as a key document for logistics, overseas warehouses, and platform compliance reviews.

Non-lithium battery products such as LR44/AG13 alkaline batteries, SR626/SR920 silver oxide batteries, and zinc-air batteries are not subject to UN38.3 regulations. If your product is incorrectly classified by the platform system, you may submit documentation including battery composition details, product specifications, actual photos, and user manuals to appeal the decision.

Special Notice: UN38.3 only addresses transportation compliance issues. When listing on Amazon's U.S. site, you must also comply with local mandatory safety regulations for button batteries. 

The U.S. Reese's Law has been implemented, with 16 CFR Part 1263, 16 CFR 1700.15/1700.20, and ANSI/UL 4200A-2022 now incorporated into CPSC's mandatory requirements. These standards focus on regulating battery compartment design, child-safety mechanisms, and ingestion warnings. The CPSC explicitly states that even if a product is not preloaded with button batteries at the time of manufacture, it must still comply with these regulations if its design is compatible with such batteries.

Amazon's compliance review policy: Selling consumer products containing button batteries requires submission of a UL4200A test report issued by an accredited laboratory, along with a GCC General Conformity Certificate issued independently by the company. Incomplete documentation will result in direct product removal or traffic restriction.

Compliance Guidelines by Scenario  

1. Selling button batteries independently 

CR series lithium coin batteries: Prepare UN38.3 test report/test summary, SDS/MSDS, battery specification sheet, compliant shipping packaging and labeling, and ensure child-safety packaging with warning labels.

Non-lithium button batteries: Exempt from UN38.3 requirements, but must comply with Reese’s Law by providing child-resistant packaging, warning labels, and product instructions.

2. Sale of finished products equipped with button batteries  

For example, remote controls, electronic scales, digital thermohygrometers, LED candle lights, musical greeting cards, keychain lights, etc. If a product contains or is designed to use button batteries, the complete unit must uniformly provide a UL4200A test report, GCC certification, full-chain warning labels, and instructions. If lithium button batteries are built-in, additional UN38.3 testing and transportation compliance documentation are required.

3. The finished product does not include a battery, but is designed to accommodate button batteries.

This type of product is not exempt from regulations and must comply with the safety requirements of UL4200A and 16 CFR 1263.

Summary:UN38.3 ensures the safety of lithium battery cross-border transportation, while UL4200A and 16 CFR 1263 address product safety during use, including protection against accidental ingestion and structural integrity. These two compliance requirements are independent yet both essential.

NBTS, a testing brand under Oushitong, recommends sellers complete three key checks before listing: confirm battery chemistry type, clarify product sales format, and verify site regulations and platform requirements. Holding multiple authoritative certifications including CNAS, CMA, and CPSC, NBTS offers one-stop compliance testing services such as UN38.3, SDS/MSDS, UL4200A, and 16 CFR 1263, helping products successfully enter cross-border channels like Amazon.