Interpretation Response #25-0057
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Commercial Vehicle Safety Alliance (CVSA)
Individual Name: Collin B. Mooney
Location State: DC Country: US
View the Interpretation Document
Response text:
February 13, 2026
Collin B. Mooney, MPA, CAE
Executive Director
Commercial Vehicle Safety Alliance
99 M Street, SE, Suite 1025
Washington, DC 20003
Reference No. 25-0057
Dear Mr. Mooney:
This letter is in response to your email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the description of hazardous materials on shipping papers. You are seeking clarification on the exception to entering the subsidiary hazard of a material on shipping papers when that material does not require a corresponding subsidiary hazard label, as stated in § 172.202(a)(3). Specifically, you ask whether a shipper or motor carrier is required to enter the subsidiary hazard class or division number on a shipping paper when the package used to transport the material is a bulk package (with a capacity over 1,000 gallons) requiring placards rather than labels.
The provision in § 172.202(a)(3) does not apply to bulk packaging requiring placards. This exception applies to situations where subsidiary hazard labels are not required in accordance with § 172.402-not situations where a placard may be used in place of a label as permitted by §§ 172.400, 172.512, or 172.514. As stated in § 172.202(a)(3), except for combustible liquids, the subsidiary hazard class(es) or subsidiary division number(s) must be entered in parentheses immediately following the primary hazard class or division number on the shipping paper. As PHMSA recognizes the wording in the exception in § 172.202(a)(3) may be causing confusion for shippers and enforcement personnel, this exception may be considered for revision in a future rulemaking.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Matthew Nickels
Acting Director
Standards and Rulemaking Division
§ 172.202(a)(3), § 172.400, § 172.402, § 172.512, § 172.514