Button battery safety - Assessment of regulatory options - Consultation paper

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Consultation Paper Questions 1 - 7

1. The ACCC considers the status quo and proposes three options to improve the safety of button batteries. Which is your preferred option and why do you prefer it to the others?

The ACCC considers the status quo and proposes three options to improve the safety of button batteries. Which is your preferred option and why do you prefer it to the others?
Option 2 - I think this option is making it a mandatory standard for the consumer good, in our case the Toy but also it is making it a requirement for all button batteries for sale or supplied with the consumer good (not pre installed) is supplied in child resistant packaging.

I do think its necessary for very clear warnings to be on packaging.

Im not sure how necessary it is to be a mandatory requirement for additional warnings to be a point of purchase.

2. What effect do you believe each of the proposed options will have in saving lives and reducing severe injuries caused by button batteries?

What effect do you believe each of the proposed options will have in saving lives and reducing severe injuries caused by button batteries?
I think it will help of course. I'm not sure how many more lives or injuries will be prevented by introducing Option 3.

I would rather see more direct consumer education rather than loading up suppliers with more and more requirements they have to meet.

I think a crack down on those dodgy manufacturers and suppliers who are importing inferior product.

I also think you can have all the warnings you like, but the consumer has to follow - i think they need better education for caring for consumer goods that contain button batteries rather than the responsibility always falling back on the supplier/manufacturer.

3. Provide comment on the ACCC’s essential requirements for secure battery compartments, child-resistant packaging and warnings and information. Are there any additional requirements that should be included?

Provide comment on the ACCC’s essential requirements for secure battery compartments, child resistant packaging and warnings and information. Are there any additional requirements that should be included?
No I think they are covered.

4. In relation to the requirement for secure battery compartments in which button batteries are only accessible with the use of a tool, do you consider that the use of a ‘tool’ should include the use of a coin? Why/why not?

In relation to the requirement for secure battery compartments in which button batteries are only accessible with the use of a tool, do you consider that the use of a ‘tool’ should include the use of a coin? Why/why not?
I wouldnt think that a coin would be a suitable 'tool' in all situations - however where it could be used it would be a better option and you would avoid the screw thread from becoming worn.

5. Do you supply products that currently meet the essential requirements for secure battery compartments, child-resistant packaging and warnings and information? If not, which requirements do your products not meet and why?

Do you supply products that currently meet the essential requirements for secure battery compartments, child resistant packaging and warnings and information? If not, which requirements do your products not meet and why?
We supply toy products to the Australian & NZ markets.
Battery operated plush toys and electronic learning aids.
Most of the battery operated toys we distribute or manufacture use AA or AAA batteries and we meet the essential requirements already with secure battery compartments and warnings. Where we use button batteries, they are in plush toys and are not intended for user removal or replacement and as such have been fully secured inside a secure battery compartment inside product.

6. Provide comment on the ACCC’s proposed information standard for warnings and information to be made available at point of sale. Are there any additional requirements that should be included for products sold online, or for unpackaged products supplied to consumers?

Provide comment on the ACCC’s proposed information standard for warnings and information to be made available at point of sale. Are there any additional requirements that should be included for products sold online, or for unpackaged products supplied to consumers?
I do think that there should be a requirement for retailers selling online to provide information about any warnings on teh packaging as the consumer doesnt have access to that at the point of purchase unlike when you are in store. I dont think its necessary for any additional point of sale warnings unless there is no packaging. I think this is the responsibility of the retailer - not the manufacturer.

As already mentioned, i also think you can have all the warnings you like, but the consumer has to follow - i think they need better education for caring for consumer goods that contain button batteries rather than the responsibility always falling back on the supplier/manufacturer.

Consultation Paper Questions 8 - 14

8. Do you agree with the proposed exemption for hearing aid devices and associated zinc air batteries? Please explain your reasons. (See section 5.2)

Do you agree with the proposed exemption for hearing aid devices and associated zinc air batteries? Why/why not? (see Section 5.3)
no comment - doesnt apply to our business so i dont feel i can answer.

9. Do you consider that any other categories of consumer goods should be exempt from any of the proposed requirements? Do you have information and data you can provide to the ACCC in support of your view?

Do you consider that any other categories of consumer goods should be exempt from any of the proposed requirements? Do you have information and data you can provide to the ACCC in support of your view?
I dont feel i can answer outside of our industry.

10 . What are the likely costs to implement each of the requirements (design changes, child resistant packaging, labelling), and what do you consider is the likely effect on prices for consumers?

What are the likely costs to implement each of the requirements (design changes, child resistant packaging, labelling), and what do you consider is the likely effect on prices for consumers?
For our business, i wouldnt expect any real change as we comply to the standards under Option 1 and 2. The only change may be to testing

11. Do you think that all potential costs to business have been considered? Can you provide any further information about the likely cost and impact of each of the options?

Do you think that all potential costs to business have been considered? Can you provide any further information about the likely cost and impact of each of the options?
Option 1 and Option 2 - i dont believe there would be any additional costs to our business as we meet these requirements already.
Option 3 - however i expect there will be additional costs to develop, manufacture, execute the additional requirements.

12. Provide comment on the transition period for the proposed options. (See section 7)

Provide comment on the transition period for the proposed options (see Section 7).
12mths i think is fine to make the adjustments necessary

13. Provide comment on the principles-based approach to a mandatory safety standard. (See section 7.2)

Provide comment on the principles based approach to a mandatory safety standard (see Section 7.2). A principles based approach: • Sets out safety principles that need to be met rather than specifying detailed standards • Incorporates external instruments for compliance tests only • Includes administrative guidance which provides examples of relevant clauses in external standards that are considered to comply with each requirement.
Sounds acceptable

14. Provide any additional information or data that you think may be useful for informing the ACCC’s recommendation to the Minister.

Provide any additional information or data that you think may be useful for informing the ACCC’s recommendation to the Minister.
nothing to add