Question of the day: Need large HV automobile batteries an inner packaging as described in (b)(3)(i) or is a strong outer packaging enough? Concerns packaging requirements for lithium batteries 49 CFR 105.20

We asked the U.S. Department of Transportation (DOT Pipeline and Hazardous Materials Safety Administration PHMSA) for a written interpretation on the following question:
Concerns packaging requirements for lithium batteries 49 CFR 105.20
 Need large HV automobile batteries an inner packaging as described in (b)(3)(i) or is a strong outer packaging enough?
 Are lithium batteries packaged in accordance with § 173.185(b)(5)  excepted from the inner packaging requirements specified in § 173.185(b)(3)(i)?
Inner packagings required for large batteries described in 173.185 (b) (5)
(lithium batteries, that weigh 12 kg  or more)?
Inner packaging is not needed.
Section 173.185(b)(5) provides exceptions for lithium batteries that weigh 12 kg (26.5 pounds) or more and have a strong impact-resistant outer casing and are otherwise packaged to prevent short circuits and damage as required by § 173.185(b)(2)
Please note:
Lithium batteries that weigh 12 kg (26.5 pounds) or more and have a strong, impact-resistant outer casing, may be packed in strong outer packagings;
in protective enclosures (for example, in fully enclosed or wooden slatted crates); or on pallets or other handling devices.
Batteries or battery assemblies must be secured to prevent inadvertent movement, and the terminals may not support the weight of other superimposed elements. Batteries or battery assemblies packaged in accordance with this paragraph are not permitted for transportation by passenger-carrying aircraft and may be transported by cargo aircraft only if approved by the Associate Administrator.
If you have to ship such large lithium batteries, we offer checklists for your transport case according to ADR, IMDG-Code and ICAO-TI / IATA-DGR including source references.
So you can check which regulations have to be observed, how you pack, label and document correctly.
You will receive all the necessary transport documents for your transport case (e.g. transport document according to ADR, IMO declaration, shipper's declaration).
You can find the respective checklist article in our portal under "Find a single checklist".
In air transport, lithium cells and lithium batteries packed without equipment may only be shipped by cargo aircraft only.

Internationally required for every transport mode:
Every lithium cell and every lithium battery must be manufactured according to the quality management program described in the transport regulations, including prototypes.
What this quality management program includes, you can find here:
For the shipping of prototypes in air transport the approval under special provision A88 of the competent national authority of the state of departure is required. This usually also includes the approval of a battery weight exceeding 35 kg (so that the special provision A99 is also covered).
When a lithium cell or lithium battery is sold to end users, the UN test series 38.3 must have been successfully passed.
The UN test series 38.3 includes the following:
Since 01.01.2020  a UN 38.3 Test Summary needs to be provided by the manufacturer and any subsequent supplier on request. We have included all required details of the UN 38.3 Test Summary in our Supplier Inquiry Form.
Our supplier inquiry form helps you to get all necessary information for logistics from the manufacturer or supplier:

You can find it under DOWNLOADS in our portal:
 For large lithium cells and batteries three more technical requirements need to be fulfilled. We´ve included the confirmation of these further technical requirements in our Supplier Inquiry Form also.

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