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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #19-0137

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 GbR

Individual Name: Eva Glimsche

Location City: München Country: DE

View the Interpretation Document

Response text:

May 5, 2020

Eva Glimsche
Lithium-Batterie-Service GbR
Sperberstr. 50e
81827 München

Reference No. 19-0137

Dear Ms. Glimsche:

This letter is in response to your December 18, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packaging requirements for large lithium batteries. Specifically, you ask if large lithium batteries packaged in accordance with § 173.185(b)(5) are excepted from the inner packaging requirements specified in § 173.185(b)(3)(i).

The answer is yes. Section 173.185(b)(5) provides exceptions for larger lithium batteries that have a strong impact resistant outer casing that would protect the battery from damage or short circuit during conditions incident to transportation. These exceptions allow certain large lithium batteries to be transported on pallets or other handling devices. Therefore, lithium batteries packaged in accordance with § 173.185(b)(5) do not require outer packaging, only the strong impact resistant outer casing that is part of the battery. The inner packagings described in § 173.185(b)(3)(i) are part of a configuration of packaging that would accompany the outer packagings described in § 173.185(b)(3)(ii). When § 173.185(b)(5) states that the large lithium batteries may be packaged in configurations other than those specified in § 173.185(b)(3)(ii) and (b)(3)(iii), that also includes the requirement that the batteries be packaged with the inner packagings in paragraph (b)(3)(i).

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


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

173.185(b)(3)(i), 173.185(b)(3)(ii),173.185(b)(3)(iii)173.185(b)(5)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries