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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 #20-0032

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Andres A. Burgos

Location State: FL Country: US

View the Interpretation Document

Response text:

May 6, 2020

Andres A. Burgos
11221 Cyprus Leave Drive
Orlando, FL  32825

Reference No. 20-0032

Dear Mr. Burgos:

This letter is in response to your April 13, 2020, email and subsequent phone conversations with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a mobility aid equipped with a lithium ion battery and transported by air. Specifically, you state that you travel with an electric scooter used as a mobility aid which is powered by a non-removable lithium ion battery that is securely attached to the scooter. You further state the battery housing provides protection from damage and the battery terminals are protected from short circuit. You seek clarification on whether you are in compliance with § 175.10(a)(17) of the HMR if you travel by aircraft with a mobility aid that has the lithium ion battery installed.

Section 175.10(a)(17) states that the requirements of the HMR do not apply to a wheelchair or other mobility aid equipped with a lithium ion battery when carried as checked baggage, provided certain provisions are met. Specifically, the lithium ion battery must be of a type that has successfully passed each test in the United Nations (UN) Manual of Tests and Criteria, as specified in § 173.185, unless approved by the Associate Administrator. The operator must verify that visual inspection of the wheelchair or other mobility aid reveals no obvious defects; battery terminals are protected from short circuits (e.g., enclosed within a battery housing); the battery must be securely attached to the mobility aid; and electrical circuits are isolated.  Additionally, the wheelchair or other mobility aid must be loaded and stowed in such a manner as to prevent its unintentional activation and its battery must be protected from short circuiting; and the wheelchair or other mobility aid must be protected from damage by the movement of baggage, mail, service items, or other cargo.

Provided both the mobility aid and the lithium ion battery contained therein meet the requirements specified in § 175.10(a)(17)(i) - (vi), the mobility aid you describe would not be subject to the requirements of the HMR when carried as checked baggage on an aircraft.

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 ,175.10(a)(17), 175.10(a)(17)(i) - (vi),

Regulation Sections

Section Subject
173.185 Lithium cells and batteries
175.10 Exceptions for passengers, crewmembers, and air operators