March 2021


New standards protect against button battery injuries

by Gail Greatorex*

Australian businesses supplying small silver ‘button’ batteries, or products that use them, must comply with new safety standards under the Australian Consumer Law (ACL).

The mandatory standards, which were declared in December, allow 18 months for businesses to gear up and ensure compliance. But only some products need that long to comply. After a long period of uncertainty, we now know what the requirements are. All businesses need to get onto implementation as soon as possible.

Catastrophic injuries

Swallowing a button battery can be catastrophic. Many deaths have occurred around the world, including three in Australia. But for those who survive such injuries, the damage can be severe and long-lasting. Young children are most likely to suffer injuries, so the impact on the rest of their lives (and their families’) can be dramatic.

Which products?

Button batteries are used in thousands of products across many consumer categories. The most common are household items, such as car keys, torches, imitation candles, scales and toys. As well as products themselves, button batteries are often in accessories, particularly remote control devices.

Importers need to conduct an audit on whether button batteries are used to operate any of their products. The new standards may require some product redesign. While that’s being done, suppliers can check whether an alternative form of power, perhaps a AAA battery, may be possible. If not, the new standards set out what must be done.

Some electrical products and their remote control devices are covered by existing electrical regulations. The new mandatory ACL product standards have made some allowances for existing regulations.

New labelling

New batteries, sold mostly in blister packs, have new requirements for child-resistant packaging and labelling.

Under the mandatory safety and information standards, products must have secure battery compartments to prevent children from gaining access to the batteries.

Manufacturers must also conduct compliance testing to demonstrate batteries are secure and place additional warnings and emergency advice on packaging and instructions.

As the vast majority of button battery powered products are made overseas, importers will need to convey clear instructions to their suppliers.

Australia has taken the lead as the first jurisdiction to introduce regulations. The Australian Competition and Consumer Commission (ACCC) has taken a principles-based approach which in some cases sets out safety principles that need to be met rather than outlining detailed specifications. This is partly to accommodate the variety of product types involved.

I am conscious that a principles-based approach needs to be applied with some caution. Clarity on what is required will be vital, especially given the variety of products to be included in the mandatory standard.


All importers need to turn their attention to this without delay. Retailers too should push their suppliers to understand and take action to ensure compliance. If a product is one of those that need the full 18 months, it will be necessary to make changes now. All other products should be made compliant as soon as it’s possible to do so. The sooner a product complies, the less chance it will be a risk to young children.

More information is available on the ACCC’s Product Safety Australia website for all businesses to understand their obligations. If in doubt, suppliers should consult their test providers and report any implementation problems to the ACCC or their industry association.

*Gail Greatorex is the owner and principal of Product Safety Solutions, in Melbourne. She was a member of the National Product Liability Association, which merged with AILA in 2019. For more information, go to

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