Health Canada has introduced new mandatory performance standards that consumer products containing button/coin batteries, button/coin batteries sold on their own, and the packaging and labelling of these products are now required to meet.1 On September 18, 2026, Health Canada added these products to Table 3 of the General Prohibitions List under the Canada Consumer Product Safety Act (“CCPSA”). Table 3 is a regulatory tool under the CCPSA that identifies classes of consumer products that pose a danger to human health or safety.2 Any product class listed on Table 3 must meet specified performance criteria — or an equivalent standard — before it can be lawfully manufactured, imported, advertised, or sold in Canada. Companies dealing in these products should treat compliance as an immediate priority.
Background
The CCPSA prohibits the manufacture, import, advertising, or sale of any consumer product that poses a danger to human health or safety. When Health Canada places a class of consumer products on Table 3 of the General Prohibitions List, it must meet the identified performance criteria listed in the Table, or an equivalent standard.
Health Canada determined that products containing button/coin batteries and button/coin batteries sold on their own may pose an ingestion hazard, leading to their addition to Table 3.3 To mitigate this hazard, Health Canada has identified performance standards that products, packaging, and labelling must now meet. The applicable standards are set out in the General Prohibitions List and are summarized in the “Actions for Industry” section below. 4
Health Canada’s approach is more flexible and less prescriptive than Reese’s Law in the US
Consistent with its general approach to Table 3 listings, Health Canada does not require companies to adopt any single named standard. Rather, Table 3 provides a list of available standards that would satisfy the certification requirement. A regulated party need only demonstrate that its product, packaging, and labelling conform to one of the listed standards, or to an equivalent standard that sufficiently mitigates the identified hazard. This gives industry latitude to rely on existing certifications, including recognized foreign or international standards, provided the substance of the safety outcome is met, and to choose among several standards depending on the type of product, packaging, or labelling at issue.
This flexible, outcomes-based approach can be contrasted with the more prescriptive regime in the United States. Reese’s Law, enacted in 2022 (codified at 16 CFR Part 1263), prescribes mandatory federal requirements for button cell or coin batteries and the consumer products that contain them. The US regime is narrower in the standards it recognizes and there is no option to certify to an “equivalent” standard.
Actions for Industry
Following the Table 3 designation, companies are prohibited from manufacturing, importing, advertising, or selling products containing button/coin batteries unless those products meet the applicable performance standards in the General Prohibitions List or an equivalent standard. Health Canada’s Table 3 designation lists break down the certification criteria by category, imposing requirements for certification for product performance, packaging (reclosable and non-reclosable), and labelling.
For products that currently meet the requirements of Reese’s Law in the US, there may be little to no further action required to ensure compliance in Canada, depending on the product’s current certifications.
For general product performance for consumer products that are not toys, Table 3 incorporates the same standard as used in Reese’s Law: ANSI/UL 4200A-2023. For general product performance for toys, Table 3 incorporates the same standard as set out in 16 CFR Part 1250: ASTM F963-23.
For packaging and labelling, while the US adopts a prescriptive approach by setting out the requirements for packaging and labelling in regulations without reference to specific standards, Health Canada’s approach relies on standards for both the packaging and labelling requirements. Many products, if already certified, may meet these requirements. However, companies should review their certifications to ensure that their packaging and labelling meet the standards (or an equivalent standard) as set out below and that certificates of conformity with those standards are available.
Products sold in reclosable packaging must meet one of the below standards or an equivalent:
- CAN/CSA Z76.1-99 (R2003): Reclosable Child-Resistant Packages; or
- ISO 8317:2015: Child resistant packaging – Requirements and testing procedures for reclosable packages; or
- the equivalent.
Products sold in non-reclosable packaging must meet one of the below standards or an equivalent:
- CSA C22.2 No. 60086-4:19 (R2024): Primary batteries – Part 4: Safety of lithium Batteries (Adopted IEC/CEI 60086-4:2014, 4th Edition, 2014-09, with Canadian deviations); or
- IEC/CEI 60086-5:2021: Primary batteries – Part 5: Safety of batteries with aqueous electrolyte; or
- ISO 28862:2018: Packaging – Child-resistant packaging – Requirements and testing procedures for non-reclosable packages for non-pharmaceutical products; or
- the equivalent.
For labelling for products containing button/coin batteries, and for button/coin batteries sold alone:
- ANSI/UL 4200A-2023: Standard for Safety for Products Incorporating Button Batteries or Coin Cell Batteries; or
- CSA C22.2 No. 62368-1:25: Audio/video, information and communication technology equipment — Part 1: Safety requirements (Binational standard with UL 62368-1); or
- ASTM F963-23: Standard Consumer Safety Specification for Toy Safety; or
- CSA C22.2 No. 60086-4:19 (R2024): Primary batteries – Part 4: Safety of lithium batteries (Adopted IEC/CEI 60086-4:2014, 4th Edition, 2014-09, with Canadian deviations); or
- IEC/CEI 60086-5: 2021: Primary batteries Part 5: Safety of batteries with aqueous electrolyte; or
- ANSI C18.3M Part 2-2024: Portable Lithium Primary Cells and Batteries – Safety Standard; or
- CSA C22.2 No. 62133-1:20: Secondary cells and batteries containing alkaline or other non-acid electrolytes – Safety requirements for portable sealed secondary cells, and for batteries made from them, for use in portable applications – Part 1: Nickel systems; or
- CSA C22.2 No. 62133-2:20: Secondary cells and batteries containing alkaline or other non-acid electrolytes – Safety requirements for portable sealed secondary cells, and for batteries made from them, for use in portable applications – Part 2: Lithium systems; or
- the equivalent.
Even if a standard does not require French/English bilingual labelling, companies selling products in Canada should be aware that in Quebec, the Charter of the French Language requires that all inscriptions on products be included in French. Companies distributing button/coin battery products into Quebec should therefore ensure that all required warnings and labelling appear in French with at least equal prominence to any English-language text, regardless of the language requirements of the applicable performance standard. Beyond regulatory compliance, adequate French-language warnings are also important from a product liability perspective.
There is no legislated coming-into-force or transition period when a class of consumer products is added to Table 3 under the CCPSA; as such, companies should treat compliance as an immediate priority. The applicable performance standard depends on the type of product, packaging, or labelling at issue, and companies must meet one of the listed standards, or an equivalent standard. Given the number of standards potentially in play, companies should review and keep all relevant documentation and certifications on hand and readily accessible, including test reports and evidence of conformance to the applicable standard.
Where a company intends to rely on an “equivalent” standard rather than one specifically named on Table 3, it should be prepared to substantiate that equivalence, since conformance with the identified performance criteria does not by itself guarantee full compliance with the CCPSA, and Health Canada retains discretion to take enforcement action wherever it has reasonable grounds to believe a product poses a danger to human health or safety.5
Footnotes
1 “Information on Health Canada’s approach to the General Prohibitions under the Canada Consumer Product Safety Act” Health Canada (September 17, 2026).
2 “Information on Health Canada’s approach to the General Prohibitions under the Canada Consumer Product Safety Act” Health Canada (September 17, 2026).
3 “Notice of danger to human health or safety and risk mitigation for products containing button or coin batteries and the packaging of button and coin batteries” Health Canada (September 17, 2026).
4 “Notice of danger to human health or safety and risk mitigation for products containing button or coin batteries and the packaging of button and coin batteries” Health Canada (September 17, 2026).
5 “Information on Health Canada’s approach to the General Prohibitions under the Canada Consumer Product Safety Act” Health Canada (September 17, 2026).
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