Interpretation Response #24-0094

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

Interpretation Response Details

Response Publish Date: 04/03/2025

Company Name: ABS All Battery Service GmbH

Individual Name: Eva Glimsche

View the Interpretation Document

Response text:

April 3, 2025

Eva Glimsche
ABS All Battery Service GmbH
Sperberstraße 50e
81827 Munich, Germany

Reference No. 24-0094

Dear Ms. Glimsche:

This letter is in response to your October 15, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium battery test reports. Specifically, may a manufacturer redact some information from a lithium battery test report and does the lithium battery test report example included with your email provide the necessary information to meet the requirements in 49 CFR § 173.185(a)(3)?

The HMR do not prohibit redaction of some information from lithium battery test reports; however, the full lithium battery test report must be made available by the manufacturer to an authorized representative of the Federal, state, or local government upon request—see 49 CFR § 173.185(a)(2)(ii).  In addition, as required by 49 CFR § 173.185(a)(3), each manufacturer and subsequent distributor must make available a lithium battery test summary that includes the following elements:

• Name and address of the cell, battery, or product manufacturer including address, telephone, email, and website;
• Name and address of the test facility including address, telephone, email, and website;
• A unique test report number;
• Date of the test report;
• Cell or battery description including if the battery is lithium ion or lithium metal, the battery's mass, watt-hour rating or lithium content, physical description of the cell/battery, and model number;
• List of tests conducted;
• Reference to assembled battery testing requirements, when applicable;
• Edition of United Nations Manual of Tests and Criteria used; and
• Name and title of responsible person.

Upon review, it appears that the redacted lithium battery test provided with your email is incomplete. Required information such as the test report number, name of testing laboratory, and name and title of responsible person are redacted.

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

Sincerely,

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

173.185(a)(2)(ii), 173.185(a)(3)

Regulation Sections