In a formal Letter of Interpretation dated August 19th, 2015 to Mr. Mike Revis USDOT/PHMSA stated categorically that a Lithium Ion Battery being shipped under the exceptions granted in 49 CFR 173.185(c) may have cells which feature watt hour ratings greater than 20 watt hours as long as the battery itself remains less than one hundred watt hours. This clarifies confusion over the issue. Many shippers wanted guidance as to whether or not a particular battery would fit in with the exceptions granted under the rule. This letter should help to alleviate some of that confusion.
Here is a link to the interpretation:
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