button cell battery

Q&A: How do I mail a product containing a lithium metal button cell battery?

A question received September 23, 2020:

Hi Daniel,

I just stumbled across your website and specifically this article: March 6, 2019: USDOT Changes Regulations for Transport of Lithium Batteries

I am trying to mail a water filter like the one in the image I attached.lithium metal button cell battery installed in equipment

When it showed up to me it had some of the UN stickers and said “forbidden for transport by air or vessel”. It does have some type of battery in it to monitor when the filter life is up.

My question is, do I need to provide one of the UN stickers on the attached image to mail it with USPS? I’m just confused if the stickers are only required for mailing batteries themselves, or if the stickers are required when there is just a battery inside the unit.

Thank you!

My reply that same day:

I will try to answer your question. Please see below.

  • To give a complete answer the size and type of the lithium cell or battery must be known.
  • However, based on the image I will presume the following:
    • It is a cell and not a battery due to its presumed size and function in the equipment. Specifically, it is a button cell.
    • It is, as you indicate, contained in the equipment it is meant to power when in it is in transportation.
    • It is a lithium metal cell and not lithium ion since it is unlikely to be rechargeable as lithium ion batteries usually are.
    • It is a “smaller” lithium metal cell. That is, it has a lithium content of no more than 1 gram if a cell and no more than 2 grams if a battery.
  • The equipment and battery must be packed securely in a good outer packaging.
  • It is not subject to any other USDOT regulations for transport within the U.S. as long as my above presumptions are correct. There is no requirement for any marks or labels on the package.
  • If the battery is packed by itself more stringent regulations apply.
  • Please refer to U.S. Postal Service (USPS) regulations.

I hope this helps. Please contact me with any other questions.

His reply the next day (09.24.21):

Lithium metal button cell batteryThank you very much for your quick reply. I have a second one of these that I cracked open to find the battery. It is a button battery about the size of a nickel, so this would NOT require any markings on the package? And for the one I will be mailing the battery will be inside the unit just as it was from the manufacturer.

What would be a normal consumer product that would require the markings when shipping? Something like an iPhone?

Thank you for the USPS website reference!!

That same day I had an answer:

Please see below.

The transportation of lithium batteries (all batteries) is very complicated. Please be advised that I am providing only general guidance.

  • If you are shipping the batteries as part of a business you are subject to more strict penalties.
  • In general:
    • “Smaller” lithium cells or batteries (those typically used in consumer devices) are subject to less regulation.
    • Lithium cells or batteries packed and shipped in the equipment they are meant to power are subject to less regulation.
    • A button cell battery contained in the equipment it is meant to power is subject to very little regulation other than safe packaging.
    • The battery in an iphone – and most other consumer items – is smaller and therefore subject to little regulation. However, it is still subject to more regulation than a button cell contained in the equipment it is meant to power.
    • The requirement for the lithium battery mark depends on the number of factors:
      • All “smaller” lithium cells or batteries packed alone or with – but not in – the equipment they are meant to power require the display of the lithium battery mark.
      • The lithium battery mark is never required for “smaller” button cells or batteries contained in equipment (your situation).
      • For other “smaller” lithium cells or batteries contained in equipment, e.g., an iPhone, the lithium battery mark must be displayed if any of the following is true:
        • More than 4 cells in a package or more than 2 packages in a consignment.
        • More than 2 batteries in a package or more than 2 packages in a consignment.
    • The mark forbidding all air and vessel transport or forbidding just passenger aircraft depends on more complicated review of regulations. Regardless, it does not apply to your situation.

Please contact me with any other questions.

The questioner wanted clarification for their specific situation:

Thank you!

So since I am just mailing one unit, with a button cell battery contained inside the equipment, I should not include any markings on the package is what I am concluding from your bullet points, correct?

My reply:

Based on the information provided, that is correct.

He was grateful:

Thank you for your time!

Conclusion:

The USDOT/PHMSA Hazardous Materials Regulations (HMR) regarding the transportation of lithium batteries of any size and any configuration are very complicated. Any time I’m asked a question I make certain to go back to the most current edition of the HMR to confirm my answer. Don’t rely on hearsay or outdated regulations! Make sure you get it right.

Q&A: What hazard communication is required on a package of a lithium metal cell (button cell battery) in equipment?

A question (09.30.20):

We are a company the produces products that contain a lithium metal cell battery as a back up battery for the time and date. The cell contains 0.015g of lithium, and the products have one of these built into them.Lithium ion button cell battery

I have gone through the training program and am certified for shipping batteries, but as you are already well aware, the regulations are a VERY difficult read. I have spent 30+ hours pouring through them thus far, largely because we use lithium metal cells and we use lithium ion batteries as well (34g of lithium in each) , and the regulations are different between them.

My question is this. In reading through 49 CFR 173.185, I am confused by the content in 173.185(c) Exceptions for smaller cells and batteries. If I am reading that correctly, as long as the singular lithium metal cell and in some models a singular lithium ion battery are built into our equipment and are mechanically secure and the product is in an OFF state, we are not required to apply the lithium warning labels on the products. Where we need apply the special markings is when we ship the cells or batteries out as a replacement part.

In your opinion, am I understanding this correctly?

Your confirmation/clarification on this would be greatly appreciated.

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
My reply that same day:

Thank you for contacting me.

You are not entirely correct. Please see below for clarification.

  • Lithium ion and lithium metal batteries have the same packaging requirements under the USDOT/PHMSA Hazardous Materials Regulations (HMR). As you indicate, these are found at 49 CFR 173.185.
  • You may be confused with the packaging requirements for transportation of lithium batteries by air according to the Dangerous Goods Regulations of the International Air Transport Association (IATA). Those have separate packing instructions for lithium ion batteries (PI 965, 966, 967) and lithium metal batteries (PI 968, 969, 970).
  • Also you refer to lithium metal cells and lithium ion batteries as having “…34g of lithium in each”. While lithium metal cells and batteries are classified according the grams (g) of lithium they contain, a lithium ion cell or battery is classified by its Watt-hour (Wh) rating.
  • Also, a lithium metal cell or battery with 34 grams of lithium metal is not a smaller lithium battery applicable for the packaging exception at 49 CFR 173.185(c). It instead is subject to full packaging requirements of 49 CFR 173.185(a-b). A lithium ion battery with a Wh rating of 34 is a smaller lithium ion battery eligible for the smaller lithium battery exception at 49 CFR 173.185(c). See below for a table summarizing the classification of lithium batteries based on lithium content.
StatusLithium Ion Battery
(Watt-hour (Wh) Rating)		Lithium Metal Battery
(Lithium Content (g))
BatteryCellBatteryCell
Subject to "smaller battery exception"Does not exceed 100 WhDoes not exceed 20 WhDoes not exceed 2 gDoes not exceed 1 g
Subject to full regulationExceeds 100 WhExceeds 20 WhExceeds 2 gExceeds 1 g
Subject to "smaller battery exception" by highway or railDoes not exceed 300 WhDoes not exceed 60 WhDoes not exceed 25 gDoes not exceed 5 g

Please forgive me if the above clarifications seem dismissive, but I wanted to clear up any misconceptions before proceeding. You are correct that the regulations for the transportation of lithium batteries are very complex.

Please see below for an answer to your question:

  • All lithium cells and batteries, regardless of lithium content or whether lithium metal or lithium ion, if contained in equipment have the same basic packaging requirements under the HMR [49 CFR 173.185(b)(4)]:
    • Outer packaging, if used, must be constructed of suitable materials of adequate strength and design…
    • Outer packaging isn’t required if batteries are contained in equipment that provides equivalent protection.
    • Equipment must be secured against movement within the outer packaging (if used, see above).
    • Equipment must be packed to prevent accidental operation during transport. Note, this is more stringent than, “…product is in an OFF state”.
  • Hazard communication per 49 CFR 173.185(c)(3):
    • A package solely of button cell batteries contained in equipment is not required to display the lithium battery mark regardless of the number of batteries or number of packages in the consignment. This may be your situation as you refer to a lithium metal cell battery as a backup battery for time and date.
    • A package solely of smaller lithium cells or batteries (not button cell) contained in equipment must display the lithium battery mark only under the following circumstances:
      • More than four (4) cells contained in equipment.

Or…

      • More than two (2) batteries contained in equipment.

Or…

      • More than two (2) packages of either per consignment.
      • So, unless your package or consignment is above one of those thresholds, the lithium battery mark is not required to be displayed on a package of a lithium cell or battery contained in equipment.
Package of Lithium Metal Battery

Smaller lithium metal battery packed alone

    • Also, pursuant to §173.185(c)(1)(iii) a package of smaller lithium cells or batteries contained in equipment must display the Cargo Aircraft Only label or a specified package mark indicating the package is not acceptable as cargo on a passenger aircraft if the net quantity of lithium battery in the package is more than 5 kg.
    • A smaller lithium cell or battery packed alone must always display the lithium battery mark. It must also display the Cargo Aircraft Only label or a specified package mark indicating the package is not acceptable as cargo on a passenger aircraft.

I suggest you contact me for further clarification.

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He didn’t. So I guess that was it.
Conclusion:

The regulations for the transportation of lithium batteries (cells or batteries) are complex and they change frequently. Another factor is the differing regulations for different modes of transport: highway and rail (i.e., ground) v. vessel v. aircraft. Contact me with questions or if you require the training necessary to safely transport lithium batteries.