New US DOT Battery Regulations Released - Dragon Innovation
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New US DOT Battery Regulations

The Federal Department of Transportation recently released updated regulations for the transport of lithium batteries (49 CFR Parts 171, 172, 173, and 175). As you can imagine, it’s a dense (30 page) read with plenty of legal jargon. After wading through it all, here are my high level takeaways.*Disclaimer – I am neither a lawyer nor a Federal regulations expert. As always, do practice due diligence and secure proper legal counsel.

    1. Batteries must be tested to meet UN38.3. The battery manufacturer has to maintain records of the testing done for this purpose for at least one year after they stop offering that battery for transportation.
    2. No other special tests need to be done and no special marks need to be a applied. This was a close one, they almost did require a new test and mark.
    3. The batteries must be marked with their capacity in W-Hrs. A battery with cells of capacity <20W-Hr, and the total battery capacity of <100 W-Hr will be exempted from some of the stricter packaging requirements but it must be marked with the capacity in W-Hrs on the battery itself.
    4. Labeling of packaging for shipment, and documentation needed for that shipment, must be coordinated with the shipping company to make sure there is no problem. Note than an individual shipping company is free to be stricter than required by the regulations
    5. The rules for batteries shipped while installed in the product are not as strict as batteries shipped by themselves as spares or replacements. In the case in which a battery is shipped by itself and not inside a product:
      • The battery must be securely packaged – most likely having its own dedicated box, just for the battery, and that box must be secured so that it cannot move around inside the larger box in which it is packaged. There should be a secure spot for it in the interior packing tray or whatever form the interior packaging takes.
      • If the battery does not conform to the requirements in #3 above, there are strict requirements for the packaging.
      • The battery should be designed, manufactured, and packaged so that accidental shorting cannot happen.
      • Drop test (from the regulations report):

      “(2) Packaging. Except when lithium cells or batteries are contained in equipment, each package must be capable of withstanding a 1.2 meter drop test, in any orientation, without
      damage to the cells or batteries contained in the package, without shifting of the contents that would allow battery-to-battery (or cell-to-cell) contact, and without release of the contents of the package.

    6. Shipment by other means (ship, truck) is allowed but packages must be properly labeled. It is my interpretation that products with a non-removable battery do not have to label the battery for capacity. From the regulations report:

(3) Hazard communication. Except for a package containing button cell
batteries installed in equipment (including circuit boards), or no more
than four lithium cells or two lithium batteries installed in the equipment:

(i) The outer package must be marked with: 

(A) An indication that the package contains ‘‘lithium metal’’ or ‘‘lithium
ion’’ cells or batteries, as appropriate;
(B) An indication that the package is to be handled with care and that a
flammable hazard exits if the package is damaged;
(C) An indication that special procedures must be followed in the event the package is damaged, to include inspection and repacking if necessary;
(D) A telephone number for additional information.

(ii) Each shipment of one or more packages marked in accordance with this paragraph must be accompanied by a document that includes the following: 

(A) An indication that the package contains ‘‘lithium metal’’ or ‘‘lithium ion’’ cells or batteries, as appropriate;
(B) An indication that the package is to be handled with care and that a flammable hazard exists if the package is damaged;
(C) An indication that special procedures must be followed in the event the package is damaged, to include inspection and repacking if necessary; and (D) A telephone number for additional information.

Dealing with these kinds of issues can be frustrating and time consuming. An efficient and effective source of help can be the company you use to ship your product. A good freight forwarder can often be very helpful with issues such as these. Bottomline, always consult an expert!

For your reading pleasure, the full battery regulations report is available here. Questions or feedback? Please let us know!

2 Comments

  • Tomas Turek commented on July 4, 2015 Reply

    What are the less stict conditions for transporting batteries within existing products? Do they have to be unplugged?

    What if the product mechanical design is a complex one and does allow design for enabling the user to plug the battery once the product is unpacked at target destination?

    • beth@dragoninnovation.com commented on July 9, 2015 Reply

      [WFD] Most regulatory schemes (UL, CE, etc.) recognize that a battery packaged inside a product is (a) protected mechanically by that product, and (b) you cannot have a lot of batteries stacked together (the product is in the way) and so the hazard is lessened. As far as I know there is no requirement or advantage to unplugging the battery, but it is sometimes a good idea anyway, especially if your ‘off’ current is high enough to discharge the battery while it is stuck in a warehouse for six months.

      With regard to your second question, I’m not sure if you meant ‘does allow’ or ‘does not allow’, but as far as I know (and as best I understand your question) it makes no difference either way from a regulatory perspective, see the answer above. Note however that if the battery is separate from the product while shipped (even if they are both in the same box) then it must be protected and packaged securely during shipping. Shipping a number of batteries together all in one box is strictly regulated – basically you cannot ship them by air and there are strict requirements for other shipping methods, such as by truck, rail, or ship. Note also that if the cell capacity is greater than 20 W-Hr or the battery itself has a capacity greater than 100 W-Hr then it is considered a high-capacity battery and the regulations on packaging, labeling, and documentation are much stricter.

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