Lithium Batteries Update

Issue 03, January 10, 2008

Effective January 1, 2008 the Department of Transportation (DOT) has issued new regulations for shipping Lithium Batteries. These regulations will be in 49 CFR Parts 100 to 185 due out in April of 2008. In the meantime you must refer to PHMSA Docket number HM-224C and 224E located on the DOT website.

Here is a link to the DOT DG webpage actually known as the Pipeline & Hazardous Materials Safety Administration:
http://hazmat.dot.gov/regs/notices/rulemake.htm#final.
You need to scroll down to get to HM-224C & 224E and can print up the documents.

The DOT controls all modes of transport to, from or within the US, so not only must a shipper be in compliance with IATA or the IMDG Code, but also must comply with 49 CFR Regulations.

Some of the changes in 49 CFR are: 1) The exception for medium batteries via aircraft and vessel has been deleted; 2) Small battery exemption from testing has been deleted; 3) Paperwork changes to both small and medium batteries shipped via highway and rail; 4) Sections 171.24 and 171.25 have been added; 5) Section 173.185 has been rewritten; 6) Special Provisions 188,189 and 190 have been added, A101, A103 and A104 have been rewritten and A102 has been removed.

Some rechargeable lithium batteries, packed in or with equipment or by themselves may be shipped as “Not Restricted” as long as the shipper complies with the Special Provisions in IATA and 49 CFR. But the forwarder/carrier still must be advised these are lithium batteries shipped as “Not Restricted” and be provided the Special Provision number.

Non-rechargeable lithium batteries packaged by themselves still cannot ride a passenger aircraft and must be shipped on cargo only aircraft. If being shipped as “Not Restricted” these still cannot ride a passenger aircraft and must have the appropriate statement marked on the package per the Special Provisions. The forwarder/carrier must be advised of Special Provision numbers.

This is just an overview of the changes. It remains every shipper’s responsibility to understand and comply with the Regulations. DHL Global Forwarding will gladly help in pointing a shipper to the Regulations. Please contact your local representative for further information.

Thank You,
Ken Hughes
U.S. Director
Export Compliance, TSA Security, Dangerous Goods
DHL Global Forwarding