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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all of my 'no longer required’s were products they deleted once I couldnt supply documentation quickly enough.

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So I am gaining insight into the button cell approval process from a new product launch perspective.

I mentioned above I went to create a shipment with a new product that contains button cells, assuming the workflow would stop me, disallow the product in my workflow, requesting certification which would need to be approved before I could send the product in. This is how it went when we were just talking about the button cells as ‘hazmat’ items. Logically, you would think they’d do it the same way with these 4200A certifications, but no, I was permitted to finish the workflow as if I were sending this product to FBA.

ANYWAY, I didn’t send anything in because I don’t know if they’ll approve my documentation, yet there is no way to submit documentation UNTIL THEY ASK FOR IT.

So exactly 20 days later, I got a notice that they wanted the documentation for this product. I uploaded it a few days ago.

And that is where I am at presently.

I am reading posts about document reviews taking 30-60 days or more, so I guess I can add that to the 20 days already spent waiting for the system to request cert. docs.

The listing page is now a dog page as of the day they requested the certification docs, so had I sent inventory in, I would be paying storage fees while my products are stranded for god-only-knows how many weeks.

FYI…

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Thanks for the update but sure wish it was less discouraging.

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Update: This morning my button cell product was approved for sale. The item was still blocked in my inventory but a few hours later it appeared unblocked.

To recap: Listing was created, then 20 days later got flagged for compliance documents (listing removed). I sent in the documentation, and 20 days later, it was approved.

I saw one post where the seller was waiting on approval for 2 months and in the meantime, Amazon slated all her FBA products for disposal because the listing was inactive for so long. Not sure how that is going for her.

Personally, I didn’t send ANY inventory in because I didn’t know if I’d get approved or not.

NOW, I have 7 more colors to create listings for to create a variation family, including this recently-approved product. I can’t wait to see how these 7 additional colors are going to go for me…My guess is some will get approved and some will be rejected…I presume I will have to re-submit documentation for each color variation…should know more in about 40 days…

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Will be interesting to see how this goes for sure. Might serve as a blueprint for doing this in a way that’s the least painful for sellers.

Thanks for sharing your journey.

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Update:

So, after the first color in my variation was approved (button cell product), I added the other colors to the family. A few days later, I was asked for certification docs for the first two I added. Those were approved 5 days later. In my subsequent submissions, I pointed out the first color that was already approved in the family, giving the reviewer some confidence to approve the others in the family.

I also mention the photos of the product they requested are within the test report, and I attach the test report again. I thought they’d reject my documents for this transgression but they’ve approved the first 3 colors in the family this way.

Today I was asked for the docs for 3 more of the colors in the family. I submitted those today.

I have not yet sent inventory to Amazon, as these items are selling fairly well without FBA anyway. So after all of this I may not bother sending them to FBA after all! You can generally get around the 4200 requirement altogether if you start a new listing and self-fulfill only. Amazon doesn’t care about button cells until you try to send them into FBA.

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Two weeks later, the 3 color variations requested most recently are still under review.
The remaining two color variations in the family still await Amazon’s request for compliance documentation.
Wildly different compliance review timelines for products listed within a day or less of each other.

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