NCQM — National Committee for Quality Management

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Industry reference

Batteries & Dangerous Goods

Transport requirements begin with material classification, package configuration and mode of transport. Lithium battery testing and test summaries support transport compliance, but do not establish every aspect of electrical, charging or end-product safety.

A product-specific review

Move from scope to evidence

  1. Define the product and activity

    Record chemistry, type, condition, quantity and whether the battery or material is shipped alone, with equipment or within equipment. Mode and route can affect the requirements. Prototype, damaged, defective and waste conditions need specific review rather than routine shipment assumptions.

  2. Connect requirements to evidence

    Connect classification and adopted test requirements with the packaging, marks, labels and documentation for the actual shipment. A UN test summary supports a defined battery type; it does not establish that every package is correctly prepared or that every related model is covered.

  3. Review interfaces and changes

    Review design and shipping changes before dispatch. Keep transport evidence separate from charging, thermal protection and end-product safety evidence. Radioactive material packages and other dangerous-goods packages have distinct approval and performance requirements within the broader transport framework.

5 source profiles

Requirements and technical resources

Review the references relevant to your product and activity. This selected federal collection does not replace a separate review of applicable state, local or contractual requirements.

Federal regulationCPSC

Button Cell and Coin Battery Product Safety

16 CFR part 1263; 15 U.S.C. § 2056e; ANSI/UL 4200A-2023 as incorporated

Reese’s Law and part 1263 address ingestion hazards from button cell and coin batteries in consumer products and packaging. Securing the compartment, resisting battery release during testing and communicating the hazard are separate obligations. Defined toy and battery exclusions must be assessed specifically. The federal incorporation of UL 4200A-2023 does not mean every battery product must purchase a private UL certification mark.

Electronics & Radio EquipmentToys & Children’s ProductsBatteries & Dangerous Goods

Federal regulationPHMSA

Hazardous Materials Employee Training and Records

49 CFR Part 172 Subpart H, especially 172.704

Hazardous materials training is organized around the functions an employee performs. The federal framework includes general awareness, function-specific instruction, safety and security awareness, with additional security-plan training where applicable. An external course certificate can support the record, but the employer must ensure that the complete training and testing obligations are met for the employee's actual duties.

Batteries & Dangerous Goods

Federal regulationPHMSA

Lithium Cell and Battery Transport Requirements

49 CFR 173.185; referenced UN Manual of Tests and Criteria, Part III, subsection 38.3

Lithium battery transport requirements address the tested cell or battery design and the shipment prepared for carriage. U.S. rules reference the United Nations subsection 38.3 test framework; this is not a standard originally developed by the U.S. government. A test summary supports design traceability, while packaging, short-circuit protection, marks, documents and transport-mode conditions require a separate shipment assessment.

Batteries & Dangerous Goods

Federal regulationPHMSA

Performance-Oriented Hazardous Materials Packaging

49 CFR 178.2; Part 178 Subparts L and M; shipper responsibilities under 173.22

A UN specification marking describes a packaging's certified design and performance scope. It does not authorize every hazardous material, quantity or closure arrangement. Packaging manufacturers establish design conformity; shippers select a permitted packaging and prepare it correctly for the contents and mode. Closure instructions and the tested configuration connect the manufactured package to its actual protective performance in transport.

Batteries & Dangerous Goods

Federal regulationNRC

Radioactive Material Transport Packaging

10 CFR Part 71

Part 71 addresses packaging and transportation of radioactive material, including package approval, design and quality assurance. The approved package configuration and authorized contents are central to its use. A package certificate does not authorize an arbitrary material, loading arrangement or operating procedure; these must be assessed against the applicable approval and transport requirements.

Nuclear Equipment & SupplyBatteries & Dangerous Goods

Build a defensible review record

Identify the product configuration, the controlling provision and edition, the evidence required and the person authorized to make the decision. Keep a reason for exclusions and unresolved questions alongside confirmed requirements.

Revisit the record when design, materials, suppliers, software, claims or the applicable source changes. An earlier report remains useful only to the extent that it supports the current configuration and requirement.

Practice guidance