On 18 September 2026, Health Canada added products containing button/coin batteries, and the packaging of button/coin batteries, to Table 3 of its approach to the General Prohibitions under the Canada Consumer Product Safety Act (CCPSA). Table 3 is Health Canada’s list of product classes it has formally determined to be a danger to human health or safety. The identified hazard is severe internal injury resulting from battery ingestion. Products and packaging that don’t meet the listed criteria, or an equivalent, can no longer be manufactured, imported, advertised, or sold in Canada.
What makes this update different
A single listing impacts three aspects of compliance: battery accessibility within the product, the packaging of loose batteries, and hazard labelling. Because each area has distinct requirements, the design, packaging, and labelling teams must work together to ensure compliance.
There’s no transition period. Paragraphs 7(a) and 8(a) of the CCPSA are already in force, so the listing applies from the day it was posted. Health Canada says it will prioritise compliance promotion after an update, but it can enforce immediately.
On the product side, Canadian requirements are closely aligned with those in the US. Both use ANSI/UL 4200A-2023 for non-toy products and require toys to meet the toy safety standard ASTM F963 requirements, so a US-compliant product is a good starting point. The Canadian packaging and labelling criteria cite different standards. Unlike the US, Canada does not currently require special packaging for zinc-air batteries. Health Canada also cites the mandatory standards from Australia’s ACCC and the UK’s PAS 7055:2021 as comparable measures.
Warnings have to be bilingual. Appendix C of the assessment gives each warning in English and French and accepts equivalent statements in both languages, so a US label written only in English needs a French translation.
Scope
The assessment defines button/coin batteries as small single-cell batteries whose diameter is greater than their height. They can be lithium, alkaline, silver oxide, or zinc-air, and run from 5 to 30 mm across. Table 3 covers three groups:
- Consumer products that are not toys: products that incorporate or use button/coin batteries, assessed against ANSI/UL 4200A-2023.
- Toys: products intended for use by a child under 14 years of age in learning or play, assessed against ASTM F963-23.
- Battery packaging: packaging for lithium, alkaline, and silver oxide button/coin batteries, with separate criteria for reclosable and non-reclosable packages. The Notice specifies that child-resistant packaging requirements apply to batteries sold separately.
Scope exclusions: Consumer products that use zinc-air button/coin batteries, and packaging for zinc-air batteries.
Key obligations
- Prohibition: No one may manufacture, import, advertise, or sell a covered product or battery package that doesn’t meet the criteria listed in Table 3, or an equivalent.
- Product criteria: Non-toy products must meet ANSI/UL 4200A-2023, and toys must meet ASTM F963-23. The assessment sorts the requirements into battery security, accessibility, captive screws, secureness, performance (use-and-abuse testing), and safety warnings, and points to sections 5.2 to 5.7, 6.1 to 6.4, and 7 of UL 4200A-2023 and 4.25.4, 5.14, and 8.5 to 8.10 of ASTM F963-23. UL 4200A-2023 generally requires a tool or coin, or two independent and simultaneous movements, to open a battery compartment by hand. These requirements are intended to reduce the risk of child access to button/coin batteries.
- Packaging criteria: Reclosable packages: CAN/CSA Z76.1-99 (R2003) or ISO 8317:2015. Non-reclosable packages: ISO 28862:2018, or Annex E of CSA C22.2 No. 60086-4:19 (R2024) for lithium batteries or Annex E of IEC 60086-5:2021 for batteries with aqueous electrolyte.
- Labelling criteria: Labelling, marking, and instruction requirements can be met under any of ANSI/UL 4200A-2023; CSA C22.2 No. 62368-1:25; ASTM F963-23; CSA C22.2 No. 60086-4:19 (R2024); IEC 60086-5:2021; ANSI C18.3M Part 2-2024; CSA C22.2 No. 62133-1:20; or CSA C22.2 No. 62133-2:20. The Notice and the assessment cite the 2024 edition of ANSI C18.3M Part 2, while the Table 3 summary lists 2023.
- Label placement: Product warnings go on the product packaging (UL 4200A-2023 and ASTM F963-23). Battery warnings go on the battery packaging, and batteries larger than 20 mm in diameter also need a label on the battery itself.
- Label content: Product-level warnings say that the product contains a button/coin battery, that swallowing can cause severe internal chemical burns in as little as 2 hours and can be fatal, that new and used batteries must be kept away from children, and that a battery that may have been swallowed or inserted into the body needs immediate medical attention. Warnings for batteries and battery packaging vary by chemistry and standard. Appendix C of the assessment has the exact wording and example labels.
- Language: Required warnings must be in both English and French, using the Appendix C wording or an equivalent statement in both languages.
- Compliance beyond the criteria: Meeting the listed criteria doesn’t make a product fully compliant with the CCPSA. Health Canada notes there may be other health or safety concerns with these or similar products and expects industry to review products for all potential hazards.
Effective dates
- Requirements became effective on 18 September 2026, when the Table 3 entry was posted.
- There is no legislated transition period. The general prohibitions were already in force.
Enforcement
Health Canada can act immediately once it has reasonable grounds to believe a product is a danger to human health or safety. The Notice lists seizure, orders to take corrective measures, orders to recall products, administrative monetary penalties, and criminal prosecution. Under Health Canada’s enforcement approach, actions are proportional to the risk a product presents, and a product doesn’t have to be on any table for Health Canada to act. This underscores the importance of immediate compliance assessment for affected products
What you should do now
With no transition window, companies should first identify which products contain button/coin batteries in their Canadian assortment.
- Inventory every SKU sold into Canada that contains or ships with a button/coin battery, including soft goods and accessories with embedded light or sound modules, and any replacement batteries supplied separately
- Audit each product against ANSI/UL 4200A-2023 (non-toys) or ASTM F963-23 (toys), using the section references in Appendix A of the assessment
- Confirm that test reports cite the 2023 editions, and map existing US reports (16 CFR Part 1263 and Part 1250) to the Canadian criteria, documenting the equivalence
- Check the packaging of batteries sold alone against the listed child-resistant standards, using the right annex for the battery chemistry, and look at spare batteries supplied with products, which the assessment identifies as a hazard scenario
- Put the required warnings in English and French on the product packaging, and on the battery itself for batteries larger than 20 mm, using the Appendix C wording or an equivalent statement
How Eurofins Softlines and Hardlines can help
We can help you evaluate product compliance with these requirements, including testing to ANSI/UL 4200A-2023 and ASTM F963-23.
Please contact us for more information.
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