This is an analysis of U.S. and International Lithium Battery
Transportation Regulations (also known as 'Dangerous Goods Regulations')
applicable to Lithium primary cells and batteries manufactured
by Panasonic and Rayovac, and used in STMicroelectronics' NVRAM
and Serial RTC products. This analysis confirms these small cells
are excepted from regulation and thus are not subjected to "Class
9" markings, labeling, documentation, or packaging requirements
(for Lithium and Lithium ion cells).
Special provisions in the aforementioned regulations provide
"exceptions" for small, consumer-type Lithium cells
and batteries. Under the current international hazardous materials
transportation regulations, Lithium primary cells that contain
not more than 1 gram of Lithium content and meet the testing requirements
in the UN Manual of Tests and Criteria, Part III, Sub-section
38.3 are not subject to other provisions contained in the
regulations.
The Lithium cells that STMicroelectronics uses in its products
that are manufactured by Panasonic and identified as Model Numbers
BR1225, BR1632, and BR2032 contain less than 1 gram of Lithium
content and meet the testing requirements in the UN Manual
of Tests and Criteria, Part III, Sub-section 38.3. Therefore,
these cells are not subject to other provisions contained therein.
This exception also applies to cells packed with or contained
in equipment. |