Interpretation Response #19-0134
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Lithium Batterie Service
Individual Name: Eva Glimsche
Location City: Munich Country: DE
View the Interpretation Document
Response text:
May 21, 2020
Eva Glimsche
Lithium Batterie Service
GbR – Sperberstr. 50e – 81827
Munich, Germany
Reference No. 19-0134
Dear Ms. Glimsche:
This letter is in response to your December 13, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of lithium ion batteries. You describe a scenario in which ear plugs or hearing aids are contained within a carrying case and the carrying case charges those items. You state that both the ear plugs / hearing aids and the carrying case contain lithium ion batteries. You ask whether the carrying case that charges the ear plugs and hearing aids is considered "UN3481, Lithium ion batteries contained in equipment" or "UN3480, Lithium ion batteries." Additionally, you ask the same question regarding the ear plugs / hearing aids.
As described in your scenario, the carrying case would be considered "UN3480, Lithium ion batteries" because the primary purpose of the carrying case is to provide electrical power to another device (i.e., the ear plugs or hearing aids). Additionally, the ear plugs or hearing aids would be considered "UN3481, Lithium ion batteries contained in equipment."
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division