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Interpretation Response #06-0079 ([House of Batteries] [Mr. Brion Munsey ])

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

Interpretation Response Details

Response Publish Date:

Company Name: House of Batteries

Individual Name: Mr. Brion Munsey 

Location State: CA Country: US

View the Interpretation Document

Response text:

Aug 22, 2006

Mr. Brion Munsey                 Reference No. 06-0079
Western Regional Sales Manager
House of Batteries
10910 Talbert Avenue
Fountain Valley, CA 92708

Dear Mr. Munsey:

This is in response to your letter and subsequent conversation with Mr. Darral Relerford concerning the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for excepted shipments of primary lithium cells and batteries. Specifically, you ask whether your primary lithium cells assembled into three-cell stacks, which you refer to as “CR2032 primary lithium coin cells” with a lithium content of 0.062g of lithium metal, are subject to the requirements in the UN Manual of Tests and Criteria for lithium batteries. According to your letter the cells, which individually conform to the UN testing requirements, are stacked one on top of the other and held together by PVC heat shrink tubing and the cells are not permanently connected together.

Based on the diagram and information provided, it appears that the “three cell stack configuration” of your “CR2032 primary lithium coin cells” containing 0.062g of lithium metal that are in direct contact with one another meets the definition for a. “battery” as described by the UN and applicable to the lithium battery provisions in § 173.185 of the HIVIR. In the United Nation’s Recommendations on the Transport of Dangerous Goods, Manual of Test and Criteria, Fourth Revised Edition the word “battery” means one or more cells that are electrically connected together by a “permanent means,” including case, terminals, and markings.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries