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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 #23-0091

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

Interpretation Response Details

Response Publish Date:

Company Name: Honda Development and Manufacturing of America

Individual Name: Mr. Joe Williamson

Location State: OH Country: US

View the Interpretation Document

Response text:

October 31, 2023

Mr. Joe Williamson
Senior Staff Engineer
Honda Development and Manufacturing of America
Purchasing and Supply Chain Planning – Strategic Planning Dept. / Business Management Unit
24000 Honda Pkwy
Marysville, OH 43040

Reference No. 23-0091

Dear Mr. Williamson:

This letter is in response to your August 4, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packaging lithium ion batteries. In your email, you describe a lithium ion battery assembly with a strong, impact-resistant outer aluminum casing enclosing the assembly, and you state that the battery and casing weigh several hundred kilograms. You further note that the battery assemblies are secured to a steel handling rack to prevent inadvertent shifting, and that the terminals do not support the weight of other superimposed elements. Specifically, you ask whether these lithium ion battery assemblies may be packaged in a steel handling rack for highway transportation—rather than in United Nations performance-oriented packaging—in accordance with § 173.185(b)(5).

Provided that the aluminum casing is strong and impact-resistant, the lithium ion batteries are secured to prevent inadvertent shifting, and the terminals do not support the weight of other superimposed elements, it is the opinion of this Office that the packing and handling arrangement you describe in your email is acceptable for highway transportation in accordance with § 173.185(b)(5).

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