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Interpretation Response #19-0129

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

Interpretation Response Details

Response Publish Date:

Company Name: Goal Zero

Individual Name: Christie Babalis

Location State: UT Country: US

View the Interpretation Document

Response text:

April 16, 2020

Christie Babalis
General Counsel
Goal Zero
675 West 14600 South
Bluffdale, UT  84065

Reference No. 19-0129

Dear Ms. Babalis:

This letter is in response to your November 8, 2019, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of an item as "UN3481, Lithium ion batteries contained in equipment, 9." You explain that your company manufactures a portable power station that contains lithium ion batteries, called the Yeti Power Station (Yeti). You explain that although the Yeti is used to provide power for external devices, it has its own operation and internal functions that use power from the batteries. These internal functions include monitoring and adjusting the charging behavior of the Yeti based on the availability of power on the input ports, specifically in relation to solar power inputs that are constantly changing. Additional functions include monitoring available power on the input ports and notifying the end user if the power inputs change within certain parameters.

Additionally, you explain that the product line was designed as two separate product types: the equipment with its own operation, and a separate battery pack to power that equipment. You provided pictures of the two product types showing the standalone battery packs and the Yeti without the battery installed. You state that these two products can be integrated into a single unit, combining the non-hazardous power station without the battery and the compatible standalone battery pack. Specifically, you seek confirmation of your understanding that when integrated, this product may be classified as "UN3481, Lithium ion batteries contained in equipment, 9."

It is the opinion of this Office that the classification of the Yeti as "UN3481, Lithium ion batteries contained in equipment, 9" is incorrect. Section 173.185 defines "equipment" as the device or apparatus for which the lithium cells or batteries will provide electrical power for its operation. While there are functions internal to the Yeti for which the battery provides power, those functions are secondary to and in support of the primary function of this unit, which is to provide power to other external pieces of equipment. Based on your description of the product, and research into this and similar products, the functions that are described for these items include providing power to smartphones, tablets, cameras, laptops, fridges, and televisions. The primary purpose of these units appears to be serving as a backup battery to items that are typically powered by a lithium battery or providing power to items powered by electricity. All other functions of the Yeti and similar units appear to support the performance of that primary function.

In accordance with § 173.22, it is the shipper's responsibility to properly class and describe a hazardous material. This Office does not perform that function. However, in consideration of the information you have provided, the Yeti's main function appears to be providing power to other pieces of equipment. Therefore, this item should be classified as "UN3480, Lithium ion batteries, 9."

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

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.185, 173.22

Regulation Sections

Section Subject
173.185 Lithium cells and batteries
173.22 Shipper's responsibility