Interpretation Response #25-0031
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Tesla
Individual Name: Ryan Bush
Location State: NV Country: US
View the Interpretation Document
Response text:
June 5, 2025
Ryan Bush, Engineering Supervisor
Tesla, 1 Electric Ave
Reno, NV 89434
Reference No. 25-0031
Dear Mr. Bush:
This letter is in response to your March 17, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to United Nations specification packaging exceptions for lithium cells and batteries. Specifically, is there a definition for "strong, impact-resistant outer casing" in the HMR?
No. There is not a specific definition for "strong, impact-resistant outer casing" in the HMR. Section 173.185(b)(5) allows shippers to package lithium cells or batteries weighing 12 kg or more, with strong, impact-resistant outer casing, using alternative packaging that demonstrates equivalency to the performance standards of Packing Group (PG) II. Furthermore, lithium cells or batteries must be secured to prevent damage caused by inadvertent shifting, the terminals must not support the weight of other superimposed elements, and the packaging must prevent short circuits. Note that PHMSA has previously interpreted the meaning of "strong, impact-resistant outer casing" for these batteries. It is the shipper's responsibility to ensure the packaging, enclosures, or other handling devices meet necessary performance standards (i.e., to withstand normal conditions incident to transportation).
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
§ 173.185(b)(2), § 173.185(b)(5)
Regulation Sections
| Section | Subject |
|---|---|
| 173.185 | Lithium cells and batteries |