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Interpretation Response #19-0013

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

Interpretation Response Details

Response Publish Date:

Company Name: Hunter Fan Company

Individual Name: Tony Bacon

Location State: TN Country: US

View the Interpretation Document

Response text:

May 15, 2019

Tony Bacon
Hunter Fan Company
7130 Goodlett Farms Parkway
Suite 400
Memphis, TN  38016

Reference No. 19-0013

Dear Mr. Bacon:

This letter is in response to your February 04, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium cells and batteries. In your email, you state the Hunter Fan company provides residential ceiling fans with a remote control and one lithium button cell battery (not installed in the remote control) in the same packaging. The packages are stacked together on a single pallet, and you ask questions regarding the marking and labeling requirements for these packages.

We have paraphrased and answered your questions as follows:

Q1. Regarding § 173.185(c)(3)(i), you ask whether the lithium battery mark must be affixed to a particular side of the package.

A1. The answer is no. Bear in mind lithium button cell batteries are not subject to the lithium battery marking when installed in equipment (i.e., installed in the remote control).

Q2. You ask if § 173.185(c)(3)(i) does not specify a particular side for the placement of the lithium battery marking, would § 172.406(a)(1)(i) be applicable to the packages.

A2. The answer is no. However, it is the opinion of this Office that affixing the marking to the surface of the package (other than the bottom), as referenced in § 172.406(a)(1)(i), would aid in eliminating any delays or hindrance of the shipment while in transportation.

Q3. You ask whether the location of the mark on the package shown in the photograph you provided is acceptable.

A3. The answer is yes. Although you are not subject to the hazard communication requirements of part 172 of the HMR, you are subject to the overpack requirements with regard to palletizing the packages in § 173.25(a).

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


Dirk DerKinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

173.185(c)(3)(i), 172.406(a)(1)(i), 173.25(a).

Regulation Sections

Section Subject
172.406 Placement of labels
173.185 Lithium cells and batteries
173.25 Authorized packagings and overpacks