{"operation":"document","citation":"25-0087","title":"ABS All Battery Service GmbH — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2026-01-16","effective_on":null,"summary":"25-0087 response to ABS All Battery Service GmbH concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0087.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0087.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0087","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2026-04/25-0087.pdf","body":"<<>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nJanuary 16, 2026\nEva Glimsche\nABS All Battery Service GmbH\nSperberstraße 50e\n81827 Munich, Germany\nReference No. 25-0087\nDear Ms. Glimsche:\nThis is in response to your June 30, 2025 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium battery test reports.\nSpecifically, you request that we revisit a previously issued Letter of Interpretation (Reference\nNo. 24-0094), which concerns the manufacturer redacting information from a lithium battery test\nreport. You ask if the lithium battery test report example included with your email provides the\nnecessary information to meet the requirements in § 173.185(a)(3)?\nNo. As stated in the previous request, the HMR do not prohibit redaction of some information\nfrom lithium battery test reports; however, the full lithium battery test report must be made\navailable by the manufacturer to an authorized representative of the Federal, state, or local\ngovernment upon request—see § 173.185(a)(2)(ii). In addition, as required by § 173.185(a)(3),\neach manufacturer and subsequent distributor must make available a lithium battery test\nsummary that includes the following elements:\n• Name and address of the cell, battery, or product manufacturer including address,\ntelephone, email, and website;\n• Name and address of the test facility, including address, telephone, email, and\nwebsite;\n• A unique test report number;\n• Date of the test report;\n• Cell or battery description including if the battery is lithium ion or lithium metal,\nthe battery’s mass, watt-hour rating or lithium content, physical description of the\ncell/battery, and model number;\n• List of tests conducted;\n• Reference to assembled battery testing requirements, when applicable;\n• Edition of United Nations (UN) Manual of Tests and Criteria used; and\n• Name and title of responsible person.\n\n<<>>\n\nUpon review—though the lithium battery test summary provided with your latest email is now\nunredacted—it remains incomplete. The name of the testing laboratory—as specified in\n§ 173.185(a)(3)(iii))—is still missing. Finally, regarding your concerns about the edition of the\nUN Manual of Tests and Criteria used, under the HMR, the edition provided in the report was\nthe version in effect at the time the test was performed.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nAlexander Wolcott\nActing Chief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\nEnclosure:\n- Copy of LOI Reference No. 24-0094\n\n<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nApril 3, 2025\nEva Glimsche\nABS All Battery Service GmbH\nSperberstraße 50e\n81827 Munich, Germany\nReference No. 24-0094\nDear Ms. Glimsche:\nThis letter is in response to your October 15, 2024, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium battery\ntest reports. Specifically, may a manufacturer redact some information from a lithium battery\ntest report and does the lithium battery test report example included with your email provide the\nnecessary information to meet the requirements in 49 CFR § 173.185(a)(3)?\nThe HMR do not prohibit redaction of some information from lithium battery test reports;\nhowever, the full lithium battery test report must be made available by the manufacturer to an\nauthorized representative of the Federal, state, or local government upon request—see 49 CFR\n§ 173.185(a)(2)(ii). In addition, as required by 49 CFR § 173.185(a)(3), each manufacturer and\nsubsequent distributor must make available a lithium battery test summary that includes the\nfollowing elements:\n• Name and address of the cell, battery, or product manufacturer including address,\ntelephone, email, and website;\n• Name and address of the test facility including address, telephone, email, and website;\n• A unique test report number;\n• Date of the test report;\n• Cell or battery description including if the battery is lithium ion or lithium metal, the\nbattery’s mass, watt-hour rating or lithium content, physical description of the\ncell/battery, and model number;\n• List of tests conducted;\n• Reference to assembled battery testing requirements, when applicable;\n• Edition of United Nations Manual of Tests and Criteria used; and\n• Name and title of responsible person.\n\n<<>>\n\nUpon review, it appears that the redacted lithium battery test provided with your email is\nincomplete. Required information such as the test report number, name of testing laboratory,\nand name and title of responsible person are redacted.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<>>\n\n25-0087\nPollack\nFrom:\nTo:\nCc:\nSubject:\nDate:\nEva Glimsche\nDodd, Alice (PHMSA)\neva.glimsche@lithium-battery-service.com; Pollack, Arthur (PHMSA); Foster, Glenn (PHMSA)\nRe: Interpretation Final Response PHMSA 24-0094\nMonday, June 30, 2025 6:49:44 AM\nSome people who received this message don't often get email from eva.glimsche@lithium-battery-service.de.\nLearn why this is important\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nDear Alice,\nfor a customer I just went to your response and reading it again I decided that I need to ask the\nquestion once more providing you with the original document we received.\nPlease review the attached document regarding the questions:\n1. The version given in the UN 38.3 test summary did not match the version of the\nManual of Tests and Criteria that was valid at the date of testing.\nWe did request the battery manufacturer to correct the UN 38.3 test summary and we\nreceived the reply that the battery was tested according to 7th revised edition even if\nthe test report was from 2023.\n2. No test institute was entered in the UN 38.3 test summary we received.\nAsking for the test institute we received the following statement:\n\"To clarify, that information does need to be passed on to regulatory authorities\nrequesting the summary like, the FAA, IATA, etc but, it does not need to be passed\non to anyone else, at our discretion. If any of those agencies need a non-redacted\ncopy, they will ask us for one. At that point, we have a \"reasonable\" amount of time\nto provide the document to them, per part 4, section H of the document you sent me.\nNobody else needs a non-redacted copy for any reason.\nIf you are requesting this document from us for transportation purposes, the copy I\nsent you will satisfy the transporters, as they do not need a non-redacted copy. I\nhope that helps.\"\nCould you please review your written letter of interpretation PHMSA 24-0094 on\nwhether the statements this battery manufacturer made under list point 1 and under\nlist point 2 reflect the PHMSAs point of view.\nSpecifically whether the wrong information on the Manual of Tests and Criteria would\nbe a „Stop“ on buying and on shipping that product and whether to enter „Confidential\nand proprietary MaxAmps information“ for UN 38.3 Test Lab would be an example of\nredaction that would be OK for PHMSA.\nPlease keep the information on the manufacturer confidential when writing your\nresponse.\n\n<<>>\n\nThank you very much.\nBest regards,\nEva\nEva Glimsche\nABS All Battery Service GmbH\nSperberstr. 50e – 81827 Munich - Germany\nOffice +49 - 89 - 43579624\nMobile +49 - 171 – 4958177\neva.glimsche@lithium-battery-service.com\nwww.lithium-battery-service.com\nCEO: Eva Glimsche and Jürgen Werny\nRegistered office: Munich\nCommercial Register: Amtsgericht München (district court Munich) HRB 296612\nSocial Media\nWe sure enjoy keeping in touch! You can do so via Facebook, Linkedin, Pinterest,\nTumblr, Twitter or Xing.\nNewsletter\nYou want to receive updates on new and changed regulations on the transport of lithium\ncells and batteries?\nVia this link you can sign up for our newsletter service:\nhttps://www.lithium-batterie-service.de/en/newsletter/\nHere you can meet us Online:\nhttps://www.lithium-batterie-service.de/en/learning-opportunities/\nAm 03.04.2025 um 20:06 schrieb Dodd, Alice (PHMSA) :\nDear Eva Glimsche,\nPlease find attached our response to your request for a letter of clarification regarding the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) under tracking number 24-\n\n<<>>\n\n0094.\nPlease submit any additional questions to our Hazmat Info Center at Infocntr@dot.gov.\nCordially,\nAlice Dodd\nAdministrative Assistant, Hazmat Standards\nUS Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave S.E. Washington, D.C. 20590\nOffice: 202-366-9141\nPHMSA Home | LinkedIn | Twitter | HAZMAT | OPS\n\n<24-0094.pdf>\n\n<<>>\n\nModel: Li-ion 25000 14S5P 50.4v Battery Pack\nUN38.3 Lithium Battery Test Summary\n1\nProduct Manufacturer\n2\nProduct Manufacturer Contact Information\n3\nUN38.3 Test Lab\nConfidential and proprietary\ninformation\nTest Report Number\n5\nDate of Test Report\n03.06.2023\n6\nDescription of Cell or Battery\nLi-ion battery\n7\nUN38.3 Tests Performed and Successfully Passed\nT.1, T.2, T.3, T.4, T.5, T.7. (Note that T.6 and T.8 are not applicable to\n8\nbatteries, only cells)\nAssembled Battery Testing Requirements\nNot Applicable\nEdition of UN Manual of Tests and Criteria Used\nRev. 7\n10\nName and Title of Signatory","truncated":false,"body_characters":9765}