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Interpretation Response #18-0142

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

Interpretation Response Details

Response Publish Date:

Company Name: Lifetime Brands, Inc.

Individual Name: Jeff Koon

Location State: IL Country: US

View the Interpretation Document

Response text:

December 20, 2018

Mr. Jeff Koon
Director of Engineering
Lifetime Brands, Inc.
2311 W. 22nd Street
Suite 200
Oak Brook, IL  60523

Reference No. 18-0142

Dear Mr. Koon:

This letter is in response to your November 14, 2018, email and subsequent phone call requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazard communication requirements for packages containing lithium button cell batteries installed in equipment.  Specifically, you ask whether packages containing lithium button cell batteries installed in equipment must display the lithium battery mark in accordance with § 173.185(c)(3).

The answer is no.  Packages containing only lithium button cell batteries installed in equipment, including circuit boards, that comply with the requirements of § 173.185(c) are not required to display the lithium battery mark.  This applies regardless of the number of packages per consignment, the number of pieces of equipment per package, or the number of lithium button cell batteries installed in each piece of equipment.

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

173.185(c)(3), 173.185(c)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries