Turn a battery-powered toy over and you may find a warning printed on it. A supplier is free to leave that one off. Four standards cover the button and coin batteries in toys, remote controls and musical greeting cards, and all four are mandatory. But inside the two that set what a warning has to say, one part binds a supplier and one only advises, and the warning meant to survive on the object itself, long after the box is in the recycling, sits in the advisory one.
The split runs right through the Consumer Goods (Products Containing Button/Coin Batteries) Information Standard 2020, one of four mandatory standards Australia has run since 22 December 2020, binding on anything supplied from 22 June 2022 onward. Part 2 of that standard is titled Requirements. Part 3 is titled Recommendations. The permanent mark on the toy sits in Part 3.
Six things a compliant warning must say
Where a warning is required at all, section 8(7) sets what it has to contain: an upper-case alert word such as DANGER, WARNING or CAUTION; a recognised safety alert symbol; a statement that the battery is hazardous and must be kept from children whether it’s new or used; a time figure for lithium cells; a description for non-lithium cells with no time figure attached; and an instruction to seek medical attention immediately if a battery is suspected swallowed or placed inside the body.
Two of the six change with the chemistry. For a lithium button or coin cell, the warning has to tell you it can cause severe or fatal injuries in two hours or less if swallowed or placed inside any part of the body. For a non-lithium cell, it only has to tell you it can cause serious injuries in the same circumstances, with no two-hour figure. Size, legibility and how long the mark has to survive handling are handed to a label-design standard, ISO 3864-2:2016 Annex D.
Where the warning is allowed to live
A toy can reach you with none of that six-part warning printed on it. Section 8(3) requires the safety alert symbol on the front panel of the packaging, clearly visible. Section 8(2) requires the full warning in the instructions, if the goods come with any. If the goods are packaged with no instructions, or aren’t packaged at all, sections 8(4) to (6) require the warning to be attached to or included with the goods, and section 8(6) allows that to be done with a sticker or a tag. A sticker satisfies the law. Lower-risk goods that come with instructions, such as hearing aids or goods with a fully enclosed battery, are excused from the packaging symbol and the attached warning, and carry theirs in the instructions alone (section 9).
The mark durable enough to outlast the box and the sticker sits in Part 3. Section 12 says the goods should carry a warning printed on the object itself, located near where the battery is accessible, durable and legible for the expected life of the goods. Section 11(2) then says outright that a supplier doesn’t contravene the instrument by failing to comply with Part 3.
The compartment is where the law bites
The design requirement lives in a different instrument: the Products Containing Button/Coin Batteries Safety Standard 2020. Section 9(1) says that where a battery is meant to be replaceable by a consumer, the compartment holding it must be designed to resist being opened by young children. Section 8(1) applies regardless of whether the battery is meant to be replaced at all: it must not release during reasonably foreseeable use or misuse. For a toy tested to AS/NZS 8124.1, section 15(1) also requires it to comply with clause 13.4.6 of the electric-toys standard, AS/NZS 62115, where that applies. Section 10(3) names that clause as the captive-screw test: a compartment door’s screws have to stay attached to it, so they can’t disappear into your couch. Where a battery isn’t meant to be replaceable but is still accessible (the standard’s own example is a musical greeting card), section 11 sends the product to a named test in UL 4200A.
You can’t tell by looking. Testing samples against clauses of published standards proves all of that, and a supplier who skips the testing has broken the law whether or not the box carries a symbol.
Put the two pieces of advice you meet next to each other. Both come in the same voice. “Check the battery compartment is screwed shut” rests on that mandatory design requirement, tested against a named clause, in force since 22 June 2022. The Royal Children’s Hospital (RCH) gives the same advice independently, in its list of ways to stop children swallowing button batteries, and its next line covers the failed check: “Throw out any toys that do not have secure battery covers.” “Look for the warning printed on the toy” rests on section 12, which recommends that warning and leaves a supplier free to skip it. One check rests on a requirement a supplier can be held to; the other rests on wording nobody has to follow.
The two checks ask different questions. The compartment check asks whether a child can get the battery out of something you already know holds one. The printed warning, where there is one, tells you the object holds a battery at all, and RCH notes that you may not even know an item has a button battery if it comes pre-installed. A missing warning proves nothing either way.
No public record shows whether the toy in your hand was ever tested against AS/NZS 8124.1: Australia doesn’t publish a register of which products passed which test.
Loose batteries carry their own two rules
A battery on its own, still in a blister pack on a shelf, is covered by two more instruments: the Button/Coin Batteries Safety Standard 2020 and its Information Standard counterpart. Section 7(1) of the Safety Standard requires the packaging itself to resist being opened by young children, and section 8(1) requires blister packaging to release only one battery at a time, a pack that spills its whole contents at once fails on its own terms. Not every cell is caught: the rule applies to any lithium single-cell battery wider than it is tall, or a non-lithium cell 16 mm or wider, so a small non-lithium cell under that width sits outside the child-resistant packaging rule. The Royal Australian Mint gives a five-cent coin as 19.41 mm across, so a 16 mm cell is a little narrower than one.
The Information Standard adds one further mark that does have to sit on the object itself: a lithium cell 20 mm or wider (a shade wider than that five-cent coin) must carry a keep-out-of-reach symbol at least 6 mm across, clearly visible and indelible. Six millimetres on a twenty-millimetre face covers a little under a third of the battery’s width. A lithium cell under 20 mm gets its required warning on the packaging alone; once you bin that packaging, that warning goes with it.
If a battery goes missing
Section 8(7)(f) requires every compliant warning to say the same final thing: get medical attention immediately if a battery is suspected to have been swallowed or placed inside the body. That wording covers more than swallowing. The Sydney Children’s Hospitals Network lists the nose, eyelids and ears among the places a button battery can become stuck. For a suspected swallow, the Royal Children’s Hospital’s Kids Health Info fact sheet gives the first step: call an ambulance (000) immediately or go straight to the nearest hospital emergency department, and do not wait for symptoms. RCH’s answer continues after that step; the fact sheet has the rest.
A child who has swallowed one can look entirely well for hours before noisy breathing, chest pain, drooling or trouble swallowing turn up; some vomit blood or pass dark stools. A button battery can burn the oesophagus in as little as two hours, the same figure the Information Standard requires printed on a lithium cell’s own warning.
What’s already in the house
A toy that was already in the house before the rules applied sits outside them. Both the Safety Standard and the Information Standard for products containing button batteries exclude goods first supplied to a consumer before 22 June 2022 (section 6(3)(a) of each), so a toy first sold before that date was never required to be tested against any of it. The same two standards leave out goods supplied in a one-off transaction by someone who had acquired them as a consumer (section 6(3)(b) of each). Selling on one toy you bought for your own child is the plain case. The compartment check still works on any toy you own.
The Royal Children’s Hospital lists keys, remote controls, calculators, musical greeting cards, watches and kitchen scales among the household products that use button batteries. Two of the four instruments, the two for products containing button batteries, apply to goods like these. Both leave out a battery soldered in place inside audio, video or IT equipment, or inside an office machine rated up to 600 volts (section 6(3) of each). The notes to that exclusion name smartphones and electronic musical instruments as examples of the first group, and calculators and cash registers of the second. Only a cell soldered in place is left out.
General information, not medical advice. Chat with your GP or child health nurse.