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Interpretation Response #08-0267 ([National Electrical Manufacturers Association] [Mr. Kyle Pitsor])

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 Electrical Manufacturers Association

Individual Name: Mr. Kyle Pitsor

Location State: VA Country: US

View the Interpretation Document

Response text:

December 10, 2008

Mr. Kyle Pitsor

National Electrical Manufacturers Association

1300 North 17th Street, Suite 1752

Rosslyn, VA 22209

Ref. No.: 08-0267

Dear Mr. Pitsor:

This is in response to your October 24, 2008 letter concerning the marking and labeling requirements for lithium metal batteries offered for transportation by aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions). You ask if you may incorporate the language shown below into a "lithium battery" handling label while maintaining compliance with the HMR and ICAO Technical Instructions.

The ICAO Technical Instructions (2009-2010) edition require certain packages containing lithium cells or batteries to bear a "lithium battery" handling label. At the same time, the HMR require the outside of each package containing primary (non-rechargeable) lithium batteries or cells to be marked "PRIMARY LITHIUM BATTERIES"FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT" or "LITHIUM METAL BATTERIES"FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT" on a background of contrasting color, in letters:

(i) At least 12 mm (0.5 inch) in height on packages having a gross mass of more than 30 kg (66 pounds); or

(ii) At least 6 mm (0.25 inch) on packages having a gross mass of 30 kg (66 pounds) or less.

Provided the package is marked as described above, the language required by the HMR may appear on a "lithium battery" handling label. The ICAO Technical Instructions are silent on

modifications to handling labels, but for other labels, minor variations that do not affect the obvious meaning of the label are acceptable.

I hope this answers your inquiry.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

172.185, 172.101

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.185 Lithium cells and batteries