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Interpretation Response #23-0040

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 (RADIX International)

Individual Name: Dennis Raymund V. Franco

Location State: VA Country: US

View the Interpretation Document

Response text:

August 17, 2023

Dennis Raymund V. Franco
Manager DG (HAZMAT) Compliance, International Affair & Compliance
DHL Global Forwarding (RADIX International)
22879 Glenn Drive, Suite 100
Sterling, VA  20164

Reference No. 23-0040

Dear Mr. Franco:

This letter is in response to your April 17, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium cells and batteries. Specifically, you seek clarification on the required lithium battery test summaries as prescribed in § 173.185(a)(3).

We have paraphrased and answered your questions as follows:

Q1. You ask whether the lithium battery test summary expires or otherwise must be renewed at intervals such as annually.

A1. The answer is no. Lithium cells and batteries manufactured according to a type meeting the requirements of part III, sub-section 38.3 of the UN Manual of Tests and Criteria, Revision 3, Amendment 1, or any subsequent revision and amendment applicable at the date of the type testing, may continue to be transported, unless otherwise provided in the HMR. The information in a lithium battery test summary linked to a specific cell/battery/device remains valid indefinitely unless otherwise specified.

Q2. If there is no alteration to the lithium battery itself, you ask what date each UN 38.3 lithium battery test summary remains valid.

A2. See answer A1. New or revised lithium battery test summary information would be required only if the cell/battery/device is of a different design that necessitated re-testing. In that instance, a new lithium battery test summary would need to be generated.

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


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries