Interpretation Response #25-0132
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: National Transportation Consultants
Individual Name: Kristopher Bowen
Location State: IN Country: US
View the Interpretation Document
Response text:
May 18, 2026
Mr. Kristopher Bowen
National Transportation Consultants
9761 Crosspoint Blvd., Suite 100
Indianapolis, IN 46256
Reference No. 25-0132
Dear Mr. Bowen:
This is in response to your October 1, 2025 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of lithium batteries contained in equipment. Specifically, you request clarification on the labeling and marking requirements for an unpackaged riding mower containing a large lithium battery transported on a trailer.
Under § 173.22, it is the shipper's responsibility to classify a hazardous material properly, in accordance with classification criteria provided in the HMR, prior to offering it for transportation to—or within—the United States. This Office does not normally perform this function. However, based on the scenario in your letter, the riding mower may be described under the Hazardous Materials Table (HMT) entry "UN3171, Battery-powered vehicle or Battery-powered equipment, 9." When transported in accordance with the provisions of § 173.220, these vehicles are excepted from the marking and labeling requirements of 49 CFR Part 172, Subparts D and E. See §§ 173.220(h)(2) and 172.102, Special Provision 134.
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
172.102 173.22 173.220(h)(2)