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Interpretation Response #08-0173 ([Cannondale Sports Group] [Mr. Zach Krapfl])

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

Interpretation Response Details

Response Publish Date:

Company Name: Cannondale Sports Group

Individual Name: Mr. Zach Krapfl

Location State: WI Country: US

View the Interpretation Document

Response text:

August 12, 2008

Mr. Zach Krapfl

Cannondale Sports Group

World Headquarters

4902 Hammersley Road

Madison, WI 53711

Ref. No.: 08-0173

Dear Mr. Krapfl:

This is in response to your July 8, 2008 letter concerning the appropriate classification of an electric bicycle powered by a lithium-ion battery under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that the battery used to power the bicycle contains 20.79 grams of equivalent lithium content. Further, you state that the battery is in the process of being tested pursuant to the requirements of the UN Manual of Tests and Criteria, Fourth Revised Edition. Specifically, you ask if your electric bicycle equipped with a lithium-ion battery may be classed and described as "Battery powered vehicle" or "Battery powered equipment" (UN3171) under the HMR.

The answer is yes. An electric bicycle powered by a lithium-ion battery is most appropriately described as a "Battery-powered vehicle" under the HMR. A vehicle powered by a lithium battery must satisfy the requirements of § 173.220(d), which requires the battery to be of a type that has successfully passed each test in the UN Manual of Tests and Criteria as specified in § 173.185, unless approved by the Associate Administrator.

I hope this information is helpful.


Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards

173.185, 173.220(d)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries
173.220 Internal combustion engines, vehicles, machinery containing internal combustion engines, battery-powered equipment or machinery, fuel cell-powered equipment or machinery