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Interpretation Response #13-0184 ([Coda Energy] [Mr. Chris Aragon])

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

Interpretation Response Details

Response Publish Date:

Company Name: Coda Energy

Individual Name: Mr. Chris Aragon

Location State: CA Country: US

View the Interpretation Document

Response text:

November 5, 2013

Mr. Chris Aragon
Coda Energy
135 E. Maple Ave. Unit C
Monrovia, CA 91016

Ref No.: 13-0184

Dear Mr. Aragon:

This is a response to your September 6, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the testing of lithium ion batteries.  Specifically, you seek confirmation that a new design type of lithium ion battery you manufacture does not require a new test in accordance with the UN Manual of Tests and Criteria due to the minimal changes in design from a previously tested battery.  In your letter, you provide the test report for your previously tested design type as well as material safety data sheets for both your previous design type and new design type of lithium ion battery.  

In accordance with § 173.185(a)(1), each lithium cell or battery must be of a type proven to meet the requirements of each applicable test of the UN Manual of Tests and Criteria found in Section 38.3.  As stated in Section of the UN Manual of Tests and Criteria, cells and batteries, which differ from a tested type, are required to be retested if, for rechargeable cells and batteries there is a change in Watt-hours of more than 20% or an increase in voltage of more than 20%; or there is a change that would materially affect the test results.

Based on the documentation you provide, the new design type battery has no changes in protective devices, hardware, and software, safety design in the cells or batteries or venting valve.  The size of the device remains the same, as does the number of component cells and the connecting mode and configuration of those cells. Based on the data you supplied the new design type of lithium ion battery exhibits an increase in voltage of approximately 14% and an increase in Watt-hours of 25%.   Since the increase in Watt-hours is over 20% new testing in accordance with Section of the UN Manual of Tests and Criteria would be required.    

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


Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries