Matching a UN 38.3 Test Summary to the Battery or Product

A UN 38.3 test summary needs an identifiable connection to the item it describes. That identifier can be the cell or battery model—or, when the summary covers a product containing a battery, the product model.

PHMSA’s July 2024 guide explicitly allows both. It also requires identifying and technical information, including manufacturer and laboratory contacts, the report number and date, a description and test results. A summary may cover multiple models if the required information is included.

If a summary names a battery while the accompanying paperwork names only a finished device, the connection still needs evidence. Similar appearance or capacity does not establish that they are the same design.

Testing and shipment preparation

49 CFR 173.185 separately addresses testing and packaging. A design-test record cannot establish that an individual package protects against short circuits, movement damage or accidental activation. Damaged or defective batteries also receive separate treatment under the rule.

PHMSA says test summaries do not simply expire with age. A different design requiring retesting needs new or revised summary information. The relevant question is whether the record still matches the design, rather than whether its date or layout looks recent.

Cover photograph: Chingo K / Wikimedia Commons; photograph source; CC BY 4.0. Original photograph retained; display crop and size variants for layout.