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NVRAM and Serial RTC
STMicroelectronics' Exemption from
Hazmat Regulations for Lithium Cells

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.

Regulatory Framework for Lithium Cells and Batteries Overview
U.S. Department of Transportation (DOT; HMR, 49 CFR, Parts 171-180)
U.S. Hazardous Materials Regulations (HMR; Title 49 CFR, Parts 100-185)
Reference exception 49 CFR, Part 173.185(b) - based only on Lithium content
International Air Transport Association (IATA; Dangerous Goods Regulations, 2004 Edition)
Special Provision A45
International Civil Aviation Organization (ICAO; Technical Instructions for the Safe Transport of Dangerous Goods by Air, 2003-2004 Edition)
Special Provision A45
International Maritime Dangerous Goods (IMDG; Code, Amendment 31)
Special Provision 188
European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR; 1 January 2003 Edition)
Special Provision 188
UN Manual of Tests and Criteria (UN Recommendation on the Transport of Dangerous Goods, Part III, Sub-section 38.3)
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Manufacturer Information
Panasonic Industrial Battery Company (Transportation Guidelines)
LiCF (BR Type) MSDS
oembatteries@panasonic.com
Rayovac Corporation (Environmental Information FAQ)
LiCF (Lithium Carbon Mono-flouride) MSDS
consumers@rayovac.com
STMicroelectronics' Environmental Protection Information