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Interpretation Response #20-0058

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

Interpretation Response Details

Response Publish Date:

Company Name: DHL Global Forwarding

Individual Name: Dennis Raymund V. Franco

Location State: VA Country: US

View the Interpretation Document

Response text:

September 15, 2020

Dennis Raymund V. Franco
Manager DG Compliance
DHL Global Forwarding
22879 Glenn Drive, Suite 100
Sterling, VA 20164

Reference No. 20-0058

Dear Mr. Franco:

This letter is in response to your August 5, 2020, email and subsequent phone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements for transporting a bicycle powered by a lithium ion battery (an "e-bike"). Specifically, you ask several questions relating to the proper classification and modes of transportation authorized for the e-bike.

Q1. You ask whether an e-bike with a 418 Watt-hour (Wh) or 504 Wh lithium ion battery installed can be transported by aircraft or vessel.

A1. The answer is yes. An e-bike powered by a lithium ion battery, transported with the battery installed, is described and classified as "UN3171, Battery-powered vehicle, 9" in accordance with § 172.102(c)(1), Special Provision 134. There is no Wh limit for a lithium ion battery installed in and powering a vehicle.

Q2. You ask whether an e-bike with a 418 Wh or 504 Wh lithium ion battery installed and described by the shipper as "UN3481, Lithium battery contained in equipment," would be authorized for transport by aircraft or vessel.

A2. See answer A1. The proper description for an e-bike transported with a lithium ion battery installed is UN3171, Battery-powered vehicle.

Q3. You ask whether all lithium ion batteries over 300 Wh are forbidden from transportation by aircraft and vessel.

A3. The answer is no. However, lithium ion batteries with a Wh rating over 300 Wh are ineligible for the small cell and battery exception in § 173.185(c). This does not prevent lithium ion batteries over 300 Wh from being transported as fully regulated Class 9 hazardous materials, subject to all applicable HMR requirements. Additionally, as discussed above, there is no Wh limit for lithium ion batteries installed in vehicles.

Q4. You ask whether there is a weight limit for overpacks containing multiple packages of small lithium batteries when transported by highway, rail or vessel. Each package of lithium batteries is prepared in accordance with the exception found in § 173.185(c).

A4. The answer is no. There is no weight limit for an overpack, or limit on the number of packages of lithium batteries allowed to be overpacked together for transportation by highway, rail, or vessel. This applies to both lithium batteries offered in accordance with the exception for smaller cells and batteries in § 173.185(c), and fully regulated lithium batteries.

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

172.102(c)(1), 173.185(c)

Regulation Sections

Section Subject
172.102 Special provisions
173.185 Lithium cells and batteries