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Interpretation Response #17-0116

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

Interpretation Response Details

Response Publish Date:

Company Name: Arvato Digital Services, LLC

Individual Name: Manuel Gonzalez

Location State: CA Country: US

View the Interpretation Document

Response text:

Manuel Gonzalez
Dangerous Goods Specialist
Arvato Digital Services, LLC
2053 E. Jay Street
Ontario, CA 91764

Reference No. 17-0116

Dear Mr. Gonzalez:

This letter is in response to your October 16, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium battery markings.  You describe the following scenario:

  • You have packages of lithium ion batteries contained in equipment (UN3481).
  • Each package contains one 42 watt-hour lithium ion battery (4 cells per battery).
  • At least 50 packages are shrink-wrapped together on a pallet to be shipped by highway.

Specifically, you ask whether each package in the shrink-wrapped pallet is required to be marked with hazard communication markings in accordance with § 173.185(c)(3).

The answer is no.  Currently, the hazard communication marking in § 173.185(c)(3) is not required on packages that contain no more than two lithium batteries. However, per the final rule titled "Hazardous Materials: Harmonization with International Standards (RRR)" [HM‑215N; 82 FR 15796], which further aligns the HMR with certain international standards, the hazard communication marking will be required after December 31, 2018, when one consignment consists of more than two packages of lithium batteries contained in equipment. Subsequently, each package in the scenario you describe will require the new standardized lithium battery mark after December 31, 2018.

I hope this information is helpful. Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

Regulation Sections

Section Subject
173.185 Lithium cells and batteries