Now to actually answer your question Mike.
NO it does not have to be in a container. Mine is not - it is however - securely fastened. The car has passed TECH about a zillion times.
You should be good to go.
In the days of LEAD ACID batteries - containers were used to keep the battery from being punctured and throwing acid all over the place. I think that's a rule that harkens back to the 70's.
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