My Button Cell Product Saga....

Selling on Amazon
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So, sometime at the end of May 2024, Amazon informed me that my products with button cell batteries needed safety certification under 4200A blah blah blah.

I contacted my supplier of the one product this was affecting, who had no idea about this new certification requirement so I didn’t have much hope they’d get anything done by my deadline of June 24.

Sure enough, Amazon started plucking my button cell product listings daily until I was left with nothing.

During this timeframe, looking more closely at the product, I discovered that it was in fact quite easy to crack the electronics case open by twisting a feature on the product and the case pops open and exposes the electronics and components and of course the batteries.

That further cemented my presumption that this product was never going to be certified for future sales on Amazon.

So now, it is September, and I just got test certification on this product from the supplier. IT PASSED. Torque testing should have failed, although I haven’t read the specifics of the lab equipment/configuration. One article I read mentions:

Pre-conditioning – stress relief and battery replacement tests as applicable
Abuse – drop (portable and hand-held products), impact, crush, torque, tension, and compression tests
Secureness – applicable to accessible button/coin cell batteries that are not intended for user removal and replacement

This has led me to the conclusion that this whole law is pointless. As a former materials testing technician, I do not understand how any test standard could be applied to products as varied as button cell products are.

Clearly, the product I am selling (intended for adults, btw) slipped through this testing procedure…

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Certification requirements don’t always reduce incidences of the problem they are trying to address. They do, however, limit accountability to the people who manufactured the item and signed off on safety. It helps absolve retailers, for example, who only sold the item because they were assured it was safe.

Obviously, it’s better when they just made the damn thing safe to begin with.

I don’t want to know, I don’t want to know.

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If a manufacturer works regularly with a specific lab, they can make anything pass. There is so much corruption in testing it’s not even remotely funny. Even the well respected labs play games to keep their clients happy and coming back.

It’s all about money - shocker right?

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The “button battery baby” story was heartbreaking.
The childs’ esophagus literally fried because the battery was stuck and eroded her esophagus. Parents fought to get a bill passed quickly. ("Reese’s Law). I believe the batteries she ingested were from a tv remote control.
My husband had a similar injury (medical negligence) and he was lucky, I identified what it had happened (cut to the esophagus during cervical surgery) so reconstructive surgery could happen immediately. Which must happen for survival. In Reese’s case, it went undetected for several days, it was too late to save her.
Although a lot of these restrictions are definitely inconvenient, they do protect the end user .

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And if the manufacturer doesn’t have a history of working with the lab, they can hire a consultant who does.

In fact, it is commonplace to hire the consultant and let the consultant decide on the lab.

Having dealt with the issues of getting a product from engineering to the market, the use of consultants was commonplace, even for some very large companies I worked for. And the product changes associated with meet the testing process were usually trivial. Now that could be do to the quality of the engineers who worked for me, or it could be the quality of the lab or the consultant.

If there is going to be adversary situation it is not going to be with the lab. Their goal is the same as the manufacturer, a product on the market.

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So now here’s the thing:

Officially I can send this in to FBA now that I have certification. This is a glow product mostly used by young adults. I do feel like the force to open the case is significant, so maybe it DID pass their torque requirement for all I know.

So I created a listing with the item, entering all the battery info required (CR2032, lithium content, yadda yadda yadda), assuming I would get stopped in my tracks until I submitted Hazmat and/or 4200A docs and waited for approval. But it looks like it will let me send inventory in without prior approval. Previously, for hazmat stuff, the workflow would stop with a big red warning that you had to send Hazmat info in to proceed.

Knowing all of the hassles people are STILL having getting their bc-powered products approved, I don’t want to send inventory in until I know they will accept my docs from my supplier. Makes sense, right?

The listing is now a few days old–I figured in a few days the bots would flag the battery content and request compliance documents. So far that hasn’t happened.

Anyone know how this is supposed to go? I am seeing on the SC forum boards some people are waiting a month or more for responses on their submissions…

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We have been fighting against the army of bots and other individuals for months. 40 ASIN’s blocked.

We have done the relevant tests, we have had to remove more than 3000 units from Amazon warehouses, we are creating the corresponding labels and stupid warnings to be able to resend them back to AMZ. But 35 of those ASIN’s are still “pending review”, for some they ask for specifications of the tests that they had not requested at the beginning, for others they ask us for photos, for the most of them we have no answer.

In short, we are having a lot of fun. :partying_face:

And in case any of you are wondering what happened to the 5 ASIN’s that are no longer under review, they have either been approved or the required documentation is "no longer required”.

Is there any emoji with a head exploding?

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:exploding_head:
:exploding_head:

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WTH is “no longer required,” Amazon?!

Feels like Amazon should compensate you for any lost sales while they were confused.

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Well… we did it itwo years ago and we succeed, but there is a suspicious voice in my paranoid head whispering that this is revenge/retaliation.

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