Trump Freezes PHMSA HM-215N: The Impact on Lithium Battery Shippers

We mentioned in our January 30th DG Digest blog that the anticipated PHMSA HM-215N Final Rule was withdrawn as a result of President Trump’s executive memoranda that put a freeze on all new regulations. Here’s some additional information on how this temporarily impacts lithium battery shippers.

As you know, the HM-215N Final Rule would have harmonized the 49 CFR HMR with the 19th revised edition of the UN Model Regulations, the 2016 IMDG Code and the 2017-2018 ICAO Technical Instructions/58th Edition of the IATA DGR.  To prepare for the new regulations becoming effective internationally on January 1st, as well as HM-215N being approved in the US, the new battery labels and marks were designed, produced and available to customers in advance.  Many battery shippers in the US have begun to purchase these new labels and markings in anticipation that HM-215N would be approved and incorporated into the 49 CFR.

Lithium Battery Handling and Class 9 Labels Prior to HM-215N Approval

 Lithium Battery Handling Label           Class 9 Label


New Lithium Battery Mark and Lithium Battery Class 9 Labels With HM-215N Approval

 New Lithium Battery Mark           New Class 9 Battery Label

So….how does the withdrawal affect customers who have purchased the new lithium battery Class 9 and new lithium battery mark labels?

It depends.

  • If you are shipping lithium batteries domestically in the US, the current 49 CFR regulations are to be followed (prior to HM-215N); therefore, the ‘old’ (lithium battery handling “Caution!” and standard Class 9) labels should be used until HM-215N is approved, at which time the ‘new’ (lithium battery mark and lithium battery Class 9) labels will be allowed for use.
  • If you are shipping lithium batteries internationally, the regulations state you may use either the ‘old’ (lithium battery handling “Caution!” and standard Class 9) labels or the ‘new’ (lithium battery mark and lithium battery Class 9) labels through December 2018. However, if these shipments travel through the US and have a 49 CFR regulated component then the ‘old’ labels should be used until HM-215N is approved.
  • Be sure to check with your carrier as well (FedEx, UPS, DHL, etc.) to determine if there are any carrier-specific policies that may have been impacted by the withdrawal of HM-215N.

For other hazardous materials impacted by the HM-215N withdrawal it is advisable to consult any transitional provisions set out in the international regulations that allow for the movement of these materials through the US under the existing requirements in the 49 CFR. Labelmaster will continue to closely monitor the situation and provide an update to this blog when more information is available regarding when HM-215N will become a Final Rule.  If you have specific questions, call us at 1.800.621.5808 and ask to speak to a member of our Regs Team or email us at

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