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Interpretation Response #15-0185 ([HDI Gauges] [Mr. Gary Rohn])

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

Interpretation Response Details

Response Publish Date:

Company Name: HDI Gauges

Individual Name: Mr. Gary Rohn

Location State: TX Country: US

View the Interpretation Document

Response text:

May 19, 2016

Mr. Gary Rohn
HDI Gauges
Electrical Engineer
4130 Directors Row
Houston, TX 77092

Ref. No.: 15-0185

Dear Mr. Rohn:

This is in response to your e-mail dated September 11, 2015 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180 applicable to the selection of the most appropriate proper shipping name for lithium batteries.   You state that you ship “battery packs” containing lithium metal batteries in two separate configurations using either two commercially available D batteries or one DD battery.  You ask if the battery packs are most appropriately classified as UN 3090, “Lithium metal batteries” or as UN 3091, “Lithium metal batteries, contained in equipment.”

The battery packs you reference in your e-mail are most appropriately classified as UN 3090, “Lithium metal batteries.”  The introductory paragraph to § 173.185 states that “equipment means the device or apparatus for which the lithium cells or batteries will provide electrical power for its operation.” Based on the information you have provided, it is the opinion of this Office that your battery packs are offered independently from any other device to which they provide electrical power, and are most appropriately described as UN 3090, “Lithium metal batteries.”

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


Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries