Interpretation Response #25-0087

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 01/16/2026

Company Name: ABS All Battery Service GmbH

Individual Name: Eva Glimsche

View the Interpretation Document

Response text:

January 16, 2026

Eva Glimsche
ABS All Battery Service GmbH
Sperberstraße 50e
81827 Munich, Germany

Reference No. 25-0087

Dear Ms. Glimsche:

This is in response to your June 30, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium battery test reports. Specifically, you request that we revisit a previously issued Letter of Interpretation (Reference No. 24-0094), which concerns the manufacturer redacting information from a lithium battery test report. You ask if the lithium battery test report example included with your email provides the necessary information to meet the requirements in § 173.185(a)(3)?

No. As stated in the previous request, the HMR do not prohibit redaction of some information from lithium battery test reports; however, the full lithium battery test report must be made available by the manufacturer to an authorized representative of the Federal, state, or local government upon request—see § 173.185(a)(2)(ii). In addition, as required by § 173.185(a)(3), each manufacturer and subsequent distributor must make available a lithium battery test summary that includes the following elements:

• Name and address of the cell, battery, or product manufacturer including address, telephone, email, and website;
   
• Name and address of the test facility, including address, telephone, email, and website;
   
• A unique test report number;
   
• Date of the test report;
   
• Cell or battery description including if the battery is lithium ion or lithium metal, the battery's mass, watt-hour rating or lithium content, physical description of the cell/battery, and model number;
   
• List of tests conducted;
   
• Reference to assembled battery testing requirements, when applicable;
   
• Edition of United Nations (UN) Manual of Tests and Criteria used; and
   
• Name and title of responsible person.

Upon review—though the lithium battery test summary provided with your latest email is now unredacted—it remains incomplete. The name of the testing laboratory—as specified in § 173.185(a)(3)(iii))—is still missing. Finally, regarding your concerns about the edition of the UN Manual of Tests and Criteria used, under the HMR, the edition provided in the report was the version in effect at the time the test was performed.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

Enclosure:
- Copy of LOI Reference No. 24-0094

173.185(a)(2)(ii) 173.185(a)(3)(iii)

Regulation Sections