Regulatory Open Forum

Does anyone know whether Reese's Law (regarding coin cell batteries) affect medical devices?  From what I can tell, Reese's Law applies to consumer products.  By definition, consumer products excludes medical devices.  I am wondering if there is a loophole in Reese's Law (16 CFR 1263).

Intertek released a 2 page FAQ on it a few days ago. I have not read it yet though:

https://www.intertek.com/batteries/resources/reeses-law-requirements-and-faqs

In the below linked webinar, the presenter addresses the question of whether the law applies to FDA regulated medical devices.  (It is near the end during the Q&A section.)

Unlocking Reese's Law: Safeguarding Children from Button Cell Hazards (intertek.com)