Since 22 June 2022, Australia has enforced mandatory standards in relation to button / coin batteries and products containing them. Button / coin batteries are small disc-shaped batteries containing lithium, zinc silver, or manganese, and are found in common household items, including children’s toys, electronic devices, watches, cameras and other consumer goods. These mandatory standards are world-first and were introduced following serious injuries of children accidentally ingesting the batteries.

It has now been one year since the commencement of these standards. On 27 June 2023, Australia’s chief consumer law regulator, the Australian Competition and Consumer Commission (ACCC) published results of its investigation into button coin battery products. The results reveal concerning levels of non-compliance with the button / coin battery information standards. For example, more than a third of products containing button batteries failed to include mandatory warnings.

As part of its investigation, the ACCC and state / territory consumer protection agencies examined more than 400 businesses and found:

34% of products containing the batteries and 28% of packs of button batteries did not include mandatory warning information or symbols (and thereby were in breach of the information standards); and

more than 90% of products and button batteries assessed likely complied with the safety standards, based on a visual inspection.

Current standards

Mandatory standardssafety standard) and that consumers are warned about the dangers (information standard). All levels of the supply chain are legally required to comply with the mandatory standards.

apply to button / coin batteries and products containing them, to ensure the batteries cannot be easily removed (

Enforcement actions

Since these standards came into effect in  June 2022, the ACCC and state / territory consumer protection agencies have issued infringement notices, seized products, negotiated voluntary recalls and sent warnings to numerous companies that failed to comply with the standards.

For example, earlier this year ( 2023), two prominent retail and homewares companies were ordered to pay  a total of nearly AU $240,000 (US $160,129) in fines after the ACCC issued them with infringement notices related to the supply of holiday novelty products containing button batteries, allegedly for failure to comply with mandatory safety and information standards.  Neither of these matters went to Court, however both examples are indicative of the ACCC’s appetite to take enforcement action for alleged non-compliance. 

What does this mean to you?

Consumer products affecting young children’s safety, including products containing button / coin batteries, are a top focus of the ACCC and are among the ACCC’s product safety priorities during 2023-24. Given the heightened regulatory scrutiny on these items and goods containing such items, this serves as a further reminder to businesses to review your compliance practices with respect to these mandatory standards, particularly focussing on product testing and packaging/labelling.  Non-compliance will be taken seriously by the regulators and managed swiftly. 

This post was co-authored by Hazel Pang (Graduate), Sophie Edgerton (Foreign Legal Associate), and Jessie Buchan (Partner).