Interpretation Response #25-0030

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

Interpretation Response Details

Response Publish Date: 03/12/2026

Company Name: Dangerous Goods of America, Inc.

Individual Name: Manuel Alejandro

Location State: FL Country: US

View the Interpretation Document

Response text:

March 12, 2026

Manuel Alejandro
Dangerous Goods of America, Inc.
DGA Hazmat App LLC
10400 NW 33rd St, Suite 230
Doral, FL  33172

Reference No. 25-0030

Dear Mr. Alejandro:

This letter is in response to your March 14, 2025 email and subsequent phone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium batteries installed in life‑saving appliances. In your email, you describe self-inflating life vests with beacons—each containing between 1 g and 2 g of lithium metal—offered for transportation by air.

We have paraphrased and answered your questions as follows:

Q1. Is the lithium battery mark—specified in § 173.185(c)(3)(i)—required on an article described "UN2990, Life-saving appliances, self-inflating?"

A1. No. When the article is properly classed, described, packaged, marked, and labeled, as "UN2990, Life-saving appliances, self-inflating” the mark specified in § 173.185(c)(3)(i) is not applicable. However, under § 173.219(b)(3) the lithium batteries contained in life-saving appliances must be “packed in accordance with § 173.185," meaning the packaging requirements in § 173.185 apply when offering "UN2990, Life saving appliances, self- inflating."

Q2. When offered for transportation by air, what quantity limitations apply to lithium metal batteries contained in "UN2990, Life-saving appliances, self-inflating?"

A2. As described in § 173.219(b)(3), lithium batteries included as part of a life-saving appliance must be packed in accordance with § 173.185 and Special Provisions A54 and A101, as applicable. When transported by aircraft, Special Provision A101 restricts the quantity of lithium metal in the batteries contained in any piece of equipment to 12 g per cell and 500 g per battery.

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

Sincerely,

Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

§§ 173.185(c)(3); 173.219(b)(3)

Regulation Sections