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Interpretation Response #18-0084

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

Interpretation Response Details

Response Publish Date:

Company Name: Ingram

Individual Name: Tim Morgan

Location State: IN Country: US

View the Interpretation Document

Response text:

October 11, 2018

Tim Morgan
1451 All Points Court
Plainfield, IN  46168

Reference No. 18-0084

Dear Mr. Morgan:

This letter is in response to your June 4, 2018, email and subsequent phone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the lithium battery mark.  Specifically, you ask if the lithium battery mark in § 173.185(c)(3) may be modified to include supplementary information in addition to the required UN identification number and phone number. 

The answer is no.  The purpose of the marking is to indicate that the package contains lithium batteries in a clear and universal way.  Changes to the marking could diminish the effectiveness of the lithium battery mark and cause confusion in transportation.  Therefore, the lithium battery mark may not be modified to include additional information to that which is required in § 173.185(c)(3).

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division



Regulation Sections

Section Subject
173.185 Lithium cells and batteries