Lithium Battery Test Summary

Understanding PHMSA’s Lithium Battery Test Summary Requirements 

As of January 1, 2022 the Pipeline and Hazardous Materials Safety Administration (PHMSA) made it a requirement for each manufacturer or distributor of lithium batteries that were made on or after January 1, 2008 to have a lithium battery test summary according to § 173.185(A)(3).

Pipeline and Hazardous Materials Safety Administration (PHMSA)

The Pipeline and Hazardous Materials Safety Administration was created in 2004 by the United States Department of Transportation. This agency was created to develop and enforce regulations and policies regarding the safe transportation of hazardous materials to protect people and the environment. The PHMSA covers all forms of transportation including pipelines. 

Why are the lithium battery test summary requirements important? 

In order to transport a lithium battery, certain tests and criteria must be met according to sub-section 38.3 of the UN Manual of Test and Criteria. Although even with these regulations in place most shippers could still not confirm if batteries were tested or not. 

To ensure that lithium batteries were being tested, the Hazardous Materials Regulations made it a requirement for manufacturers to make lithium battery test summaries part of what is needed in the UN Manual of Tests and Criteria. The Pipeline and Hazardous Materials Safety Administration adopted this and made it effective January 1, 2022 requiring a test summary for any lithium batteries manufactured on or after January 1, 2008. This is a requirement for domestic AND international transportation. 

What is included in the lithium battery test summary?

According to the CFR  § 173.185(A)(3).

“ Each manufacturer and subsequent distributor of lithium cells or batteries, except for button cells installed in equipment (including circuit boards), manufactured on or after January 1, 2008, must make a test summary available. The test summary must include the following elements:” 

“(i) Name of cell, battery, or product manufacturer, as applicable;”

“(ii) Cell, battery, or product manufacturer’s contact information to include address, telephone number, email address, and website for more information;”

“(iii) Name of the test laboratory, to include address, telephone number, email address, and website for more information;”

“(iv) A unique test report identification number;”

“(v) Date of test report;”

“(vi) Description of cell or battery to include at a minimum;”

“(A) Lithium ion or lithium metal cell or battery;”

“(B) Mass of cell or battery;”

“(C) Watt-hour rating, or lithium content;”

“(D) Physical description of the cell/battery; and”

“(E) Cell or battery model number or, alternatively, if the test summary is established for a product containing a cell or battery, the product model number.”

“(vii) List of tests conducted and results (i.e., pass/fail);”

“(viii) Reference to assembled battery testing requirements (if applicable);”

“(ix) Reference to the revised edition of the UN Manual of Tests and Criteria used and to amendments thereto, if any; and”

“(x) Name and title of a responsible person as an indication of the validity of information provided.”

All information in this section was taken from the Code of Federal Regulations (https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-C/part-173/subpart-E/section-173.185)

Lithium Battery Test Summary

Any Questions?

We’re here to help! If you have any questions about the lithium battery test summary requirements or need assistance with your compliance needs, don’t hesitate to reach out. Our team of experts at DGM Boston is ready to provide the guidance and support you need.