Button Battery Safety Issues Paper - Australian Competition and Consumer Commission

Response 950100591

Introduction

3. What is your organisation?

Organisation

Catch.com.au Pty Ltd

4. Do you consent to ACCC publishing your submission?

Please select one item

(Required)

Yes

Yes, but do not publish my name

5. How would you like to provide your submission?

Please select one item

(Required)

Complete questions online

Upload submission

Issues Paper Questions 1 - 7

3. What information can you provide on the range of products that you supply that contain button batteries?

No data at this time

4. Do you think the recommended safety actions in the Industry Code for Consumer Goods that Contain Button Batteries (Code) for products that contain button batteries are adequate to reduce the risk of children accessing button batteries? Please provide the reasons for your response.

Yes, we are already applying the same principles

5. Do you think the recommended safety actions in the Code should be made mandatory? What impact would mandating these requirements have on Australian suppliers?

Yes. If not made mandatory suppliers and retailers will not be operating on a level playing field.
It should also be applied to overseas sellers who are offering products directly to customers with no consideration to safety.

6. If you are a supplier, do you supply products that comply with the Code?

If no, please explain why

Yes we do, we have been working towards this outcome for around 18 months.

If yes, what actions do you have in place to reflect the code?

We have an internal policy on button cell batteries ands products that use them, including requirements that they be secured by means of a screw or similar
design that prevents child access.

7. What other research and development activities are you aware of that are directed toward:

a. improving button battery safety

We issue safety guides to 3rd party sellers who use our marketplace.

b. improving the safety of consumer products containing button batteries

We include warnings with products, we also include warnings on on advertisements related to all battery types.

Issues Paper Questions 8-15

8. Would a mandated safety standard for the security of battery compartments of products containing button batteries be likely to reduce the number of injuries and fatalities caused by button batteries in Australia? Please provide the reasons for your response.

We believe it would.

9. Would a mandated safety standard and/or an information standard for child resistant packaging and labelling be likely to reduce the number of injuries and fatalities caused by button batteries in Australia? Should any such standard require provision of Australian Poison Information Centre details? Please provide the reasons for your response.

We believe this would increase the safety and reduce exposure to children

10. If it is your view that child resistant packaging and labelling requirements should be mandated, do you think this should apply to all button batteries regardless of size or chemistry? Please provide the reasons for your response.

Yes, it would become complicated to manage different chemistry types, our approach has been to apply equally as even an alkaline button cell could pose a potential choking hazard.

11. In your view, should any consumer products containing button batteries be banned from supply in Australia? If yes, please provide the reasons for your response.

No. There are ways to manage safety without a complete ban.
AS/NZS 62115 currently has requirements, perhaps this standard should be considered as a regulatory option to improve product and consumer safety.

12. If any of these requirements were mandated in Australia, what additional cost would be imposed on Australian suppliers or a relevant supplier segment?

The costs for responsible suppliers would not be an issue, the cost to irresponsible suppliers may be significant as it would limit the range of products they sell

13. If you are a supplier, what information can you provide on the actual or likely cost of implementing the safety standard and information standard for button batteries (outlined in Section 18.2) and for products that you sell?

We do not see it as a cost, rather part of our responsibility.

14. Are there any button battery products that you think should be exempted from any mandatory safety or information standards? Please provide the reasons for your response.