AJ Networks — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration April 2, 2025 1200 New Jersey Avenue, SE Washington, DC 20590 Austin Yang Manager AJ Networks 14F, AJ Bldg, 8-9, Jeongui-ro, Songpa-gu Seoul, Korea 05836 Reference No. 24-0115 Dear Mr. Yang: This letter is in response to your October 14, 2024 email and subsequent email conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to prototype and low-production run lithium battery packaging requirements in § 173.185(e). Specifically, in your email, you describe a packaging arrangement in which a battery is placed inside of a fiberboard box with polyethylene foam blocks to secure the battery against shifting. The fiberboard box is subsequently surrounded by non-combustible, electrically non-conductive material and placed into an outer packaging. We have paraphrased and answered your questions as follows: Q1. Can the packaging requirements in § 173.185(e)(1) for a prototype or low-production run lithium battery be met in the manner described in your letter, that is by surrounding an inner packaging with non-combustible, electrically non-conductive cushioning material? A1. Yes. In accordance with § 173.185(e)(1), each prototype or low-production run cell or battery must be individually packed in a non-metallic inner packaging, inside an outer packaging, and must be surrounded by cushioning material that is non-combustible and electrically non-conductive, or contained in equipment. The packaging arrangement described in your letter appears to meet the requirements of § 173.185(e), provided the cushioning material prevents shifting of the batteries within the package that may lead to damage and a dangerous condition. Q2. Is there a registration requirement or authorization process to use performance-oriented packaging (e.g., a 4G fiberboard box) following successful completion of the required tests in Part 178, Subpart M? A2. No. There is no requirement to register, obtain prior approval from PHMSA, or submit records of successful tests to the Department of Transportation to use a non-bulk#

Page 2performance-oriented packaging. Test records must be retained and provided to a representative of the Department of Transportation upon request—see § 178.601(l). Q3. Can a non-bulk performance-oriented packaging that has passed the design tests required in Part 178, Subpart M and has been marked in accordance § 178.503 be used to transport hazardous materials? A3. Yes. Each performance-oriented packaging must be marked with the name and address or symbol of the manufacturer or the approval agency certifying compliance with Subpart L and Subpart M of Part 178. Symbols, if used, must be registered with the Associate Administrator. This marking certifies that the packaging design complies with the applicable requirements of the HMR. 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#

Page 324-0115 Jones, Jessie Jane (PHMSA) Patrick From: INFOCNTR (PHMSA) Sent: Thursday, October 31, 2024 11:24 AM To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: Attachments: AJ Networks Company Profile (US)_240910.pdf FW: Inquiry about prototype lithium battery packaging - 49 CFR 173.185(e) Hi Alice, Please see the below and attached interpretation request. Let me know if you need anything. Regards, -Breanna From: 양정보/Austin Yang <rangbo@ajnet.co.kr> Sent: Monday, October 14, 2024 11:48 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Cc: seohj@ajnet.co.kr; '신명근/Phillip Shin' <phillip.shin@ajnet.co.kr>; lcycy214@ajnet.co.kr; swjung28@ajnet.co.kr; '이수길 과장(패키징R&D팀)' <sglee4310@ajnet.co.kr> Subject: Inquiry about prototype lithium battery packaging - 49 CFR 173.185(e) CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Dear DOT representative, Hello, This is Austin Yang from AJ Networks, South Korea. AJ Networks is one of the largest packaging solution company in South Korea, doing package supply business with Korean secondary battery manufacturers, plan to set up new US branch in MI. Please refer to attached company profile of us. We are curruntly in the compliance check phase in packaging design development with customer, contacting you because there are some provisions that require advice from the authority. the product to be packaged is a proto type lithium battery module, we reviewed relevant regulation, 49 CFR 173.185(e) our initial packaging concept was as below : 1#

Page 41st Concept Development Focus  Cushioning material : PE Foam  Inner package : Fiberbaord box (4G)  Outer Package : Plywood box (4D)  Net mass of battery : 31kg – over 30kg, 1 battery per outer packaging / 49 CFR 173.185(e)(3)  Plan to manufacture the package in US However, through the compliance review session, we found other critical factor to consider, non-combustible and electrically non-conductive cushioning material :  49 CFR 173.185(e)(1) Except as provided in paragraph (e)(5) of this section, each cell or battery is individually packed in a non-metallic inner packaging, inside an outer packaging, and is surrounded by cushioning material that is non-combustible and electrically non- conductive, or contained in equipment. Equipment must be constructed or packaged in a manner as to prevent accidental operation during transport;  49 CFR 173.185(e)(2) Appropriate measures shall be taken to minimize the effects of vibration and shocks and prevent shifting of the cells or batteries within the package that may lead to damage and a dangerous condition during transport. Cushioning material that is non- combustible and electrically non-conductive may be used to meet this requirement; Here is our questions : 1) Surrounding Inner package with non-combustible and electrically non-conductive cushioning material in outer package Seeing our 1st concept, could it fulfil the regulation if we surround inner package(fiberboard box) with non- combustible and electrically non-conductive cushioning material? -. we would like to keep 1st concept of inner package including PE Foam, -. but we will revise outer package design, attaching non-combustible and electrically non-conductive cushioning material inside of the outer package to make cushioning material surrounds inner package. Please find below revised concept that upper details are reflected. I would appreciate it if you could review this concept meets the relevant provisions. 2#

Page 52nd Concept 2) Packaging authorization from DOT After the POP testing, if it passes, is there a packaging registration or authorization process to DOT with testing report? As far as we reviewed, no such regulation exists for 4D and 4G to be authrized from DOT, but periodic testing is mandatory, surely if DOT request test report, it should be provided. so, only passed testing report and appropriate marking in accordance with regulation 49 CFR 178.503 is requried to use the package? We would greatly appreciate your insights and feedback. We look forward to hearing from you. Thank you. 3#

Page 6Best regards, 글로벌사업팀 양정보 / 과장 Global Business Team Austin Yang / Manager 14F, AJ Bldg, 8-9, Jeongui-ro, Songpa-gu Seoul, Korea (ZIP: 05836) Tel (82)10-7225-4829 E-MAIL : rangbo@ajnet.co.kr ajnetworks.co.kr 4#

Page 7TAJ Networks AJ NETWORKS CO.,LTD. (HQ) AJ LOGISVALUE USA INC.#

Page 8AJ Networks is the largest rental company in the Korea, provides diverse business solutions as a global business partner to customers. Logis (pallet) AWP & Forklift Business Korea M/S Sales Quantity 2nd Ranked (32%) 178 M USD 14 M Approx. 20,000 Approx. 300,000 Business 1st Ranked (19%) 76 M USD 917 million USD Affiliated IT Overseas Corporations AJ Total AJ Daewon AJ Maintenance Partners AJ Energy AJ ICT 1st Ranked (34%) 188 M USD USA, Vietnam, Saudi, Poland, Hungary Food & Logistics Facility management Vehicle management Oil distribution Management IT Outsourcing 39 M USD 20 M USD 29 M USD 318 M USD 33 M USD KSCI franchise, Global Cold Chain (Vietnam) GC management of large leisure Complex AI facility management 230 networks of equipment in Korea 8 direct gas stations 32 affiliated gas stations Operation of IT Contact Center 2#

Page 9          Georgia ※ Additional overseas corporations will be established (China, Mexico)    3#

Page 103PLs Returnable Pallet 60,000 SF (32%) 5,574㎡ Office Storage Rack 100,000 SF (52%) 9,290㎡ In/Out area 32,000 SF (16%) 2,972㎡ 4#

Page 113. AJ Logis Value USA Warehouse Photo 01 Exterior Office 03 Storing space ay Al LogisValue#

Page 12KD Box for Hyundai GLOVIS 2 1 BMA Box for Hyundai MOBIS Image Image Purpose KD Returnable Purpose Feeding box for battery process line Effect• Saving Cost (Waste of disposable packing) • Time efficiency Effect• Suitable boxes to process line Progress Development (with GLOVIS) Bidding Awarded Mass Production Progress Development Bidding Awarded (with MOBIS) Mass Production 6#

Page 134. Packaging product line-up Name Returnable Pallet Name Returnable CKD case Product Packed Products Product CKD Products Inside Inside Material Injection PP Material Injection PP Danpla (PP Corrugated Sheet) Steel Outside Outside 11A 11c Medium packaging Box Large packaging Box Large packaging Box Image Image (Light Weight) (heavy & large) 11B 11D 12A 13B#

Page 14Rail Gripper Guide 1780mm Rail 658mm 2392mm 8#

Page 154. Packaging product line-up Name Battery Storage Rack Name Battery Steel Case Product Battery Pack (PHEV, EV) Product Module Inside Inside EPP Foam Material Steel, Rubber, Urethane Material Outside Outside Steel 1300x1000x86Rmn Image Image#

Page 165. Packaging cleaning facilities Operating 43 pallet cleaning facilities in Korea (14 Automatic, 29 Manual) 10#

Page 17Thank you ajnetworks.co.kr © AJ Networks Corporation. All rights reserved, Disclaimer: This content is general information purposes only, and should not be used as a substitute for consultation with professional advisors.#