 All right, let's get started here. Welcome everyone to today's webinar, Breaking Down Reese's Law. My name is Stefan Lee. I'm a program specialist with the Small Business Ombudsman Team and I will be your presenter today. A couple of housekeeping things before we get started here. The webinar is recorded and will be available for viewing afterwards on YouTube. A PDF of the slide will be distributed via email to all registrants, whether they attended or not, and the slide deck will be available on our business guidance page for button sell and coin batteries. Any questions should be submitted through the go-to webinar interface. Unanswered questions will be addressed in the days following the webinar. Throughout this presentation, there are a few polling questions where you can gauge your knowledge of the requirements. And one last thing, the requirements that we're going to go over today are relatively high level just to make sure that the main topics are going to be covered. Nuanced issues or questions should be submitted through the go-to webinar interface. And alternatively, you can contact the Small Business Ombudsman Team directly with your inquiry. Our contact information will be available at the end of the presentation. All right, so today's agenda, we're going to be going over the background of Reese's Law, the Special Packaging Requirements 16 CFR Part 1263, which is where the requirements are codified or will be codified. A couple of enforcement discursions, the effective date summary certification. And then at the end, if we have some time, we'll be going over some questions and answers. So Reese's Law also referred to as PL 117-171 was enacted in 2022. Section two of Reese's Law requires CPSC to promulgate rulemaking for consumer products containing or designed to use button sell or coin batteries. Section three of Reese's Law requires button sell or coin batteries to utilize special packaging. So the first thing we're going to go over here is the special packaging requirements. So what it basically is, is that the packaging of button sell or coin batteries, not the battery compartment of an actual product, must meet the specifications of 16 CFR section 1700.15. Those of you who are pretty well versed in the special packaging requirements will recognize this as the PPPA requirements. So you can go to cpsc.gov.pppa for guidance on special packaging. This requirement under section three of Reese's Law does not apply to products that meet the marking and packaging provisions of the ANSI standard C18.3M. Because these products are excluded from this requirement, products that meet this ANSI standard do not need to list the public law 117-171 on the certificate. We'll be going over that later on these slides. Likewise, that means that if the product isn't subject to any other requirements, these types of products wouldn't need a certificate. The next requirement we're going to go over is 16 CFR part 1263 with the exception of section, subsection 0.4. So pursuant to section two of Reese's Law, we've incorporated the NCUL standard of 4200A-2023. It outlines performance and labeling requirements for consumer products containing or designed to use button sell or coin batteries. Keep in mind that the product itself doesn't necessarily have to contain the button sell or coin battery. If it's capable of using that battery, it would be considered subject. This requirement does not apply to children's toys already subject to a battery requirement under 16 CFR part 1250, which incorporates by reference ASTM F963. It also doesn't apply to zinc air button sell or coin batteries. So what are the requirements are outlined in the UL standard, and we're going to go over them a little here. The first requirement is that the battery compartment must be difficult for children to access. These are the different options for what would be considered difficult for children to access. The compartment is completely sealed. It doesn't allow the battery to be removed or replaced. A specialized tool is required to open the compartment, or the opening of the compartment requires at least two independent and simultaneous actions. And again, these are different options. All three of them do not have to be met simultaneously. Battery compartments that use screws or similar fasteners must use captive screws or fasteners except for the following. If the battery is only accessible through the removal of multiple enclosures or panels using a tool, the screws or fasteners do not have to be captive. Likewise, if the product is only to be opened by a professional service center, the screws or fasteners do not have to be captive either. For both of these exceptions, there must be instructions and warnings clearly stating that the battery is not to be replaced by the consumer. And for the second exception, products using screws that can be opened by common household tools may not necessarily be considered intended to be opened by a professional service center. So keep those in mind when you're relying on these exceptions. So we've come up on our first question here. Are retail displays with Trimi buttons subject if they contain a button cell or coin battery? So I'll give you guys a few seconds here to respond. And it looks like a majority of the people here said yes, the retail displays would be subject. And that is correct. So Trimi buttons, including those in retail displays, are within the scope of the final rule because they are intended to be used by consumers. For more information on this, go see the federal register post. That specific link will take you to the comment and response where this scenario is discussed. Next, we're going to go over the performance requirements. These are basically the testing requirements for the products. Batteries must not be accessible or liberated as a result of abuse testing. This testing is done in sequence. So one right after the next, sorry, one right after the other. And there are certain tests that may not apply to specific products. So some of these are situational tests. First test here is the stress relief test. It is only for compartments made of plastic. So what you would do is place it in an oven for seven hours, temperature set to the greater of 70 degrees Celsius or 10 degrees Celsius higher than the max operating temperature. The next is the battery replacement test. This is only for compartments intended to be opened. Basically, you're just life cycling the compartments open, replace the battery and close the compartment 10 times. Next is the drop test. This is only for portable or handheld products. The UL standard does define a handheld product as something that is reasonably foreseeable to be used or misused while being held in one or both hands. Products specifically designed to be carried easily with a mass of at most 4.5 kilograms. A portable device is a device that is reasonably foreseeable to be routinely carried or lifted as part of its use or misuse, but not operated during transit with a mass at most 18 kilograms. These definitions are in the UL standard. So this test consists of dropping it from a height of one meter onto a hardwood surface, at least 13 millimeters thick, mounted on two layers of nominal 19 millimeter thick plywood placed on concrete or an equivalent substrate. Next test here is the impact test. So this would apply to all products. A steel sphere 50.8 millimeters in diameter is dropped or swung as a pendulum onto the compartment from a height that induces two joules of force. This is repeated three times. And again, remember we're doing this test on one single sample one after the next. Next test is the crush test. So applying 300 plus or plus or minus five newtons of force for 10 seconds to expose surfaces using a flat surface measuring approximately 100 by 250 millimeters. Next is the torque test. It's only for compartments that can be grasped with fingers or teeth. You basically follow the torque test from ASTM F963 with a torque value of 0.50 newton meters. Next is the tension test. Again, only for compartments that can be grasped with fingers or teeth. Likewise, you run the tension test from the ASTM F963 with a force of 72 newtons. And then last, there is the compression test. It's only for accessible compartments that are inaccessible to a flat surface during the drop test. You run the compression test from the ASTM F963 with a force of 136 newtons. Now, once you run all these tests, you would run the accessibility testing that's outlined in the UL standard to see if the battery is accessible. All right, we have our next question here. Are there exceptions for button cell or coin batteries that are not intended to be removable? Let's see what most people have responded. So it looks like most people have responded yes. Unfortunately, that is incorrect. There is no exception. Neither Reese's Law, 16 CFR part 1263, or the UL standard provide for an exception for batteries that are not intended to be removable. In fact, the UL standard actually has some labeling requirements that are specific for batteries that are not intended to be removed or replaced. Plus, there are also kind of specific performance requirements for such products. The next question here. Are products with batteries not intended to be removed or replaced subject to abuse testing? All right, and it looks like most people here have answered yes. And that is correct. The abuse tests are to determine if a battery is liberated and or accessible due to potential misuse and not whether the battery housing is considered adequate for housing, from keeping the battery being accessible. So all products would be subject to the use in abuse testing, again, situationally. All right, so now we're going to go over the labeling requirements. These are outlined in section seven of the UL standard. Must be in English, prominent, legible, easily discernible, and permanent. If the label is printed in color, it must follow the color scheme of the example figures in the UL standard. There are minimum size requirements for the labeling. The safety triangle must and the text must meet the size requirements in table seven A of the UL standard. The safety triangle that has the battery icon must be seven by nine millimeters. And the circular icon of the parent holding the box above the child is eight millimeters in diameter. Labels that are not on the package or the product have different size requirements according to section seven eight point A of the standard. All right, so the packaging, the package labeling requirements, so packaging and any accompanying literature must bear specifics, the specific warning outlined here. There's two different icons that can be used. You're more than welcome to use either icon. There's no specific situation which calls for one or the other. Just make sure that you know the size requirement for those specific icons. Again, the triangle icon is seven by nine millimeters. And the circular icon is eight millimeters in diameter. So looking at this label here, the word warning is going to be the signal word. The statement ingestion hazard is the statement of hazard. And then everything else is considered other text. And this is referring to that table in seven eight, a seven eight point eight. For packages that have limited space, they can use alternative labeling. The principal display panel must bear this first warning here. And the secondary panel can show this second warning. And that secondary panel basically can be anywhere else on the package. There's also another allowance for products that don't have any packaging at all. That full label that you saw in the previous slide must be on a hang tag or a sticker label on the product itself. For the purposes of the discussion, the principal display panel is the display panel for retail package that is most likely to be displayed, shown, presented or examined under normal or customary conditions of display. Typically it's going to be the front of the package or the main panel where all the graphics and advertising is. The secondary display panel is any panel opposite or next to the principal display panel, typically going to be the side or the back. The package must also bear these statements, the identity of the battery type, the nominal voltage of the battery, and depending on whether the product actually has a non-removable battery, a statement indicating that the product contains a non-replaceable battery. And the product itself also has labeling requirements. The full label for the product label is as follows. A product with a small surface area that cannot bear the full warning label can use the icon provided that that icon is defined elsewhere in instructional pamphlets or some kind of inserts. And then products with a surface not practical for labeling, whether that's going to be because there's very little surface area or it's just too rough to get any kind of labeling on there. It has to have packaging that bears the full labeling or they can use a hang tag or sticker that bears the full labeling affixed to the product. Again, that triangle is going to be seven by nine millimeters even when it's placed on the product. And if you are using the labels in color, they must follow this color scheme. Here's another question for you guys. Does the on-product marking have to be an adhesive label? And it looks like most people have answered no. And that is correct. The markings can be part of the mold or applied using means other than adhesive label, basically laser etching it on or something similar. There is a permanent permanency test that needs to be applied under section 7D of the UL standard. And we have some other labeling requirements. So instructions and manuals that accompany the product must include specific statements. So all products have to have these following statements not going to go over them all. They're all outlined in the UL standard. These are kind of word for word prescribed. So just make sure you're just copy paste these statements. There's also separate requirements for products with replaceable batteries. So these are the statements that you need to add in addition to those statements from before. If you have a product with a non-replaceable battery, then just the statement indicating that the product contains non-replaceable batteries instead of these four statements. Now we're going to go over the labeling requirement under 16 CFR section 1263.4. So this is going to be the labeling for packages of button seller coin batteries that are sold or packaged separately. Such products must bear this warning on their principal display panel. The text and triangle, all the sizes are basically the same as the UL 4208 table and this icon is eight millimeters in diameter. This text does differ slightly from the UL standards. So just kind of keep that in mind when you're differentiating between these labels. There is an allowance for packaging with limited space. The principal display panel has to bear this circle icon, which now needs to be 20 millimeters in diameter. And the secondary display panel has to have this text. It can be bunched up as you see here in place on the secondary display panel. Labels for batteries sold separately must also include the following statements are similar. Keep in original packaging until ready for use and immediately dispose of used batteries and keep away from children. Do not dispose of batteries in household trash. This does not apply to packaging of batteries that are sold with the product. So there's a couple of enforcement discretions for the requirements that we just discussed. For the special packaging requirements, which was section three of Reese's law, there is an enforcement discretion for zinc air button sell or coin batteries. For these products manufactured or imported, the effective date is March 8th, 2024. For all other battery types, the requirements are currently in effect. The other enforcement discretion is going to be for the testing and labeling requirements of the NCUL standard. It now applies to products manufactured or imported after March 19th, 2024. This includes general use and children's products. This enforcement applies to both. We are currently aware of a letter submitted by the CTA requesting an extension of this enforcement discretion period, which ends currently March 19th, 2024. This letter is on the docket for review. You can find the letter at regulations.gov. Look for the docket number CPSC-2023-0004. And we're also aware of others who may be submitting similar letter requests for an extension. I recommend that you guys keep an eye on the CPSC's federal register post to stay up to date on the results of this request for an extension. You can also sign up for SBO's business education newsletter by visiting CPSC.gov slash email and check the box for business education. If you have any information either for or against this extension, you can submit them to the office of the secretary at CPSC-OS at CPSC.gov. So I know there's a lot of requirements that we went over. So I've created this handy little chart for you guys to take a look at, kind of summarizing the effective dates. This is also found on our button cell and coin battery FAQ page. So for the first product, first product type is going to be the actual button cell or coin battery packaging. That's going to be the special packaging requirements. So this applies to products manufactured or imported after February 12th, 2023. So again, this requirement is already in effect. Zinc air batteries, they have to be in special packaging on or after March 8th, 2024. Products containing or designed to use button cell or coin battery must meet the performance and labeling requirements of the UL standard. And this is effective March 19th, 2024, based on that enforcement discretion. And the labeling of the button cell or coin battery packaging per 16 CFR section 1263.4. This will apply to products manufactured or imported after September 21st, 2024. Now we're going to go over the certification requirements. Per the Consumer Product Safety Act, every domestic manufacturer or importer of a product subject to a mandatory consumer product safety rule must issue a certificate of compliance that they meet the rule based on passing test results. So this is going to be a general certificate of conformity for general use products or a children's product certificate for children's products which are products primarily designed or intended for children 12 years of age and under. These two certificates are pretty much identical because they contain the same information. It's just easy to differentiate between a general use product or general use certificate and then a children's product certificate. We do have illustrative examples of a certificate that they're available at the links on your screen there. Those links will also take you to the more detailed information of what the information required of a certificate are. Speaking of, these are the seven pieces of information that's required of all certificates regardless of whether it's a children's product or a general use product. Familiarize yourself with these seven elements, but the one in particular we're going to go over today is the section two which is the citation to each safety rule. So depending on the product that you guys are responsible for, there's a couple of different citations that you need to familiarize yourself with. The first is going to be PL117-171 section 3A. So this is going to be section three of Reese's Law that require special packaging of button cell or coin batteries. The second citation is 16 CFR section 1263.3. This is the consumer products containing button cell or coin batteries for the NCEUL standard. The last one is going to be 16 CFR section 1263.4. That's going to be the labeling requirements for button cell or coin battery packaging. So we're nearing the end of our presentation here. Here's a couple of resources that might be helpful. The first is our button cell or coin battery business guidance page. It outlines all of the requirements, has a link to FAQs, some helpful information there. We also have our business guidance library that compiles all of the business guidance pages that we have on our website. And finally we have our business education playlist on YouTube. That's where this recording of this of the webinar will be posted. I would also like to take this time to note that the FAQs that are associated with the button cell and coin battery business guidance page will be updated and in accordance with all the questions that we've been receiving. And again a PDF of the slides will be distributed via email to all registered attendees. It'll also be posted on this business guidance page with a link to the video. That concludes our presentation for today. Here is the small business ombudsman contact information. You can reach us in any of the ways mentioned here. And again if you'd like to subscribe to our newsletter go to cpsc.gov slash newsroom slash subscribe and check the box for business education. All right and since we have some time here we'll be going over a couple of some questions. All right so the first one question here is a what is a captive fastener. So a captive fastener or a screw is basically going to be anything that remains with the door or compartment or product when it's fully unscrewed. So basically the screw doesn't fall out because there's something on the other end of it that keeps it keeps it contained to the door the product etc. Another question here are we required to print in color on the packaging or can we choose? You do not have to print in color you can use a black and white label for the packaging as long as it meets the format and all the other applicable requirements. If you are printing in color you do need to use the color scheme that's that's referenced in the UL standard. I'd be very careful with grayscale imaging. If you're not using colors stick to just black and white otherwise use the color printing. Does the keep away icon need to be blue or can it be black and white? So this is referring to that circular icon. Again the UL standard does allow for this icon to be not in color so it can be black and white. If you are using color then use that blue in the reference to the UL standard. So we've got a lot of questions here so bear with me. Is there a choice to mark the packaging or the item or must we mark both if we can? So the labeling requirements of the UL standard are for both the packaging and the product as applicable. So if there's limited space you may not need to label the product so that's kind of situational depending on the specifics of your product but the baseline requirement is that both the packaging and the product does need to be labeled. Regarding label permanency is the Sutherland rub test required for hang tags or is that test more intended for permanent markings like laser etching? So this permanency test is more for the on-product labeling requirements. We do understand that the substrate for things like packaging or hang tags or even the instructions obviously these substrates are mostly paper so this rub test is going to just dissolve away that paper. So this permanency test is for the product itself. Next question here. If there is a product photo on the principal display panel of packaging that is in color, does a warning label then have to use color? Not necessarily again the UL standard does allow for it to be in black and white. However I would caution just to say that if you're printing your package, the rest of your packaging color then you probably should consider printing the warning label in color because it shouldn't be that much of a difference there. You're only really using one or two extra colors. If we engrave the warning on the product do we have to color it? No again that color requirement is only if you're using more than one color so if you're engraving it and you're just kind of using whatever color is on the product you don't have to try and fill in a yellow color or something like that. What is considered an adhesive label? Is this on the cell, on the bulk box, or in the carded retail of the product? This may be referring to the alternative labeling requirements under the UL standard. If not please let me know and I'll get back to you on this one. So this is basically just any sticker label whether that's going to be on the product or the packaging or whatever the UL standard kind of dictates. We do recommend that it be some kind of a stronger adhesive label something that won't be easily detached when either shipping or being handled at retail but it's basically for any alternative it's intended to to house any kind of labeling when the alternatives need to be met for the labeling under the UL standard. Next question here do you need instructions if no packages are used if so can you print the instructions on the back of the hang tag? So if there's no packaging and there's no kind of instructional pamphlet the UL standard does state that the statements under section nine of the standard do have to be on a hang tag or sticker label therefore these instructions can be on the back of a hang tag or something similar however you get it basically connected to or associated with the product. Is there a size requirement on the hang tag for non-package items? Yes the UL standard under section 7a.8 I believe has a size requirements for labeling that's intended to be on a hang tag or instructions and manuals. So also the text of instructions and manuals would need to follow this text size requirement as well. It is separate from the table that is in the UL standard that dictates the size requirements for labeling on the packaging and the product. Next question here is there a performance requirement to evaluate fastener retention. I believe the UL standard does not have this performance requirement to evaluate the fastener retention however the use and abuse testing probably is a good means of determining whether the fastener is considered captive or not. If it pops out during the use and abuse testing then it might call into question whether that fastener is considered captive and also whether it's compliant with the other performance requirements. Here's a question regarding certificates. Can the overseas manufacturer issue the GCC or does it have to be the U.S. importer slash retailer issuing the GCC? So the certificate requirements under the Consumer Product Safety Act applies to the domestic manufacturer or the importer record. Now the responsible party which is the domestic manufacturer or the importer record can rely on a third party's testing or certificate that allowances under 16 CFR part 1109. So basically the manufacturer can issue a GCC and then the importer would have to basically generate their own GCC based on the manufacturer certificate and then maintain the manufacturer the foreign manufacturer certificate as their documentation of proof that the product was tested to and meets the applicable requirements. There is some due diligence on the importer to make sure that the manufacturer actually did the testing and isn't just giving them a piece of paper that has the seven pieces of information so something like requesting the actual test results may be warranted here. Retailers do not have a requirement for issuing a GCC. We do recommend that retailers request GCCs for products that are subject to a requirement and then maintain them for their own records. Question here would children's non-toy items that contain button cell batteries but pass ASTM F960 testing still require to comply with these labeling requirements? Yes they would. So if it's a non-toy a children's non-toy item technically wouldn't be subject to ASTM F963 but rather it would be subject to 16 CFR 1263.3 so you have to rely on those requirements instead of the ASTM standard. Question here so it looks like this question is asking about the area calculation for a cylindrical package. There is some guidance on under the Federal Hazardous Substances Act at 16 CFR section 1500.121 that talks about calculating the principal display panel. For a cylinder it actually states that it is going to be 40% of the height times the circumference of the cylindrical package so that's going to be a principal display panel area and then you would calculate your size based on that. Here's a question about special packaging for the special package testing are you requiring both child and adult testing? Yes we are because the the Reese's law states that the special packaging must meet the provisions of 16 CFR section 1700.15 and that does include both child testing and senior adult testing. Is the battery warning symbol artwork file available for download? The battery coin symbol while similar to the IAC standard is not exactly the same. IAC is tilted slightly more than the coin symbol published in the UL standard. I believe the Federal Register notice does state that similar icons can be used depending on how similar they actually are. I would definitely refer you back to the Federal Register notice to look for the specific icons that they referenced in this specific comment and response. Off the top of my head I'm not sure which comment response number that is but it's definitely in that first Federal Register notice that talks about incorporating the UL standard so definitely take a look there. Question here asking about whether the requirements do not apply to built-in coin batteries that provide necessary power to operate the product but also to built-in coin batteries that maintain functions such as clocks and memory that records previous settings. Both scenarios would apply the law does not differentiate between these two types of scenarios if the product contains or is designed to use a button cell or coin battery unless certain exceptions apply it would be subject to 16 CFR 1263.3. Question here about the limited space on packaging. When space is extremely limited can the bottom back or side of the package be considered the principal display panel? Unfortunately no the UL standard is pretty clear on what the principal display panel is going to be that's basically where the main graphics are or essentially the front of the product so firms are going to have to figure out a way to either shift some graphics around to accommodate at least that partial label on the principal display panel. Are these regulations enforced for batteries manufactured prior to the dates listed for manufacturing or importing? This is going to be a little tricky to answer so I'm going to go back to this effective date summary page here so if we're talking about batteries that are intended to be used in a consumer product the date that we're going to be looking at is the date of the manufacturer of the finished product so not when the battery was manufactured but when the finished product was put together and packaged for the purposes of either import or sale. So that's going to be that third the third row there so that's going to be the March 19th date if we're talking about kind of separate batteries that are packaged or sold separately that's going to be the first the first line unless it's a same-care battery so depending on you know what kind of battery that you you are manufacturing or importing if we're talking about stuff that's manufactured overseas because the effective dates do include import date you're going to have to pay attention to the date of import which is basically whenever the shipment arrives at the ports and makes formal entry that's going to be the import date so taking it to example this the first effective date here for button seller coin battery packaging let's say the battery was manufactured in January 2023 but it makes entry now because the requirements are effective now regardless of that battery's date of manufacture it has to meet these requirements when it's crossing the border. Are the labels required on the product itself is it possible to replace it by displaying on a package that the product came in referring back to the UL standard if the product has enough space on the product display panel to accommodate either that full label let's go back here either this full label or the icon then you have to bear that full label or the icon if there's not enough space for either of these then and only then can you have either packaging that bears full label or a hang tag and sticker that bears the full label. Do these requirements apply to adult consumer products or is a child consumer product so these this requirements 16 CFR part 1263 does apply to both children's products and general use products there's no differentiation between the two except for children's toys because they're subject to the toy standard. Question about non-replaceable batteries if the battery is if the coin battery is built in and bonded to the electronic circuit with solder and the coin battery does not come out is proper labeling required so technically it would be considered a product that contains a button seller coin battery it may not be intended to be replaced or removed therefore you use that the alternative labeling for start products with a non-replaceable or non-replaceable battery. It looks like there's a question here about medical devices so medical devices are going to be a little tricky under the Consumer Product Safety Act medical devices are excluded from the definition of a consumer product and because 16 CFR part 1263 is technically referring to consumer products medical devices would not be subject to 16 CFR part 1263 however medical devices are not excluded from the definition of a hazardous substance under the Federal Hazardous Substances Act and children's products that contain hazardous substance are considered banned hazardous substances therefore basically what I'm saying here is that children's medical devices and or and or medical devices that pose certain hazards may be subject to CPSC's corrective actions such as recalls. These would be kind of tackled on a case-by-case basis if if you have a particular if you have a children's product a children's sorry children's medical device that has a button seller coin battery and it fails to meet the requirements for because it poses a hazard or for some some reason like that definitely report it and we'd work with the FDA potentially we'd work with the FDA to figure out what the appropriate corrective actions are going to be there again this is handled on a case-by-case basis so there's not a really a one-size-fits-all kind of scenario. Question here does the term product mean the button sell battery or the device that uses the battery or both so depending on which requirement we're talking about here it's going to be either the actual button sell battery or the device going back to this table so for these first two product types the product is going to be the battery itself for the third one it's the product is going to be the actual product that houses the battery and for this fourth one is going to be again the battery itself all right for literature such as an owner's manual can manufacturers add a slip sheet with the warning label and and required copy as a loose sheet or stapled if yes does the paper printed on need to be of a certain color so I believe this is talking about the literature instructions or manuals manual requirements so those labeling is under section nine of the UL standard if for whatever reason you need to bear that warning label on the instruction or manual because of an alternative requirement under the UL standard that is definitely acceptable it does not necessarily need to be in color if you are using color definitely recommend that you follow that color scheme yes and it also can be just kind of a loose sheet of paper either stapled with it's it's effectively would be considered an insert question here about the enforcement discretion clarification about the enforcement discretion what about product that is already on store shelves at retail so based on this table that's on the screen here again the effective date or rather the scope is going to be for products manufactured or imported after those respective dates so products that are currently in the United States whether they're in distribution centers in warehouses or on retail shelves would not be considered within scope because they were not manufactured or imported after the effective dates question here on online warnings are there requirements for online warnings the current requirements do not include anything about online warning statements I believe that was a part of the previous notice of proposed rulemaking but the UL standard for warning labels does not mention anything and I do believe the labeling of batteries under 12 under 16 CFR section 12 63.4 also does not have any online warning requirements there's a question about whether the enforcement discretion will be extended again as discussed previously we are aware of requests to extend this enforcement discretion date there's really nothing that we can say about it at this time other than to keep an eye out on the federal register post to see if an extension will be granted all right it looks like we're running out of time a little bit here so I will stop at this time I'll definitely get back to anybody who does who have outstanding questions and we'll be able to answer them directly in the upcoming days for the webinar again you can contact the small business ombudsman here's our contact information again if you want to take a look and feel free to send us any of your inquiries thank you for attending today's webinar and hope you guys have a great day