Interpretation Response #25-0065
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Karmanterra, LLC
Individual Name: Mark Samuels
Location State: CA Country: US
View the Interpretation Document
Response text:
June 11, 2026
Mr. Mark Samuels
President
Karmanterra LLC
2011 Palomar Airport Rd. Ste. 101
Carlsbad, CA 92011
Reference No. 25-0065
Dear Mr. Samuels:
This letter is in response to your May 12, 2025, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of your charcoal-based product, currently classed as a Division 4.2 (Spontaneously Combustible) material. According to your letter, you have conducted United Nation (UN) Test N.4 (Test method for self-heating substances) through an independent International Organization for Standardization (ISO) / International Electrochemical Commission (IEC) 17025–accredited laboratory to evaluate the self-heating properties of the material. You state that the test results demonstrate your product does not exhibit self-heating behavior as defined in § 173.124(b)(2). You ask whether your testing supports a determination that your pine-derived biocarbon does not meet the definition of a Division 4.2 hazardous material.
As specified in § 173.22 of the HMR, it is the shipper's responsibility to properly class and describe a hazardous material. Such determinations are not required to be verified by this Office. Furthermore, the Pipeline and Hazardous Materials Safety Administration does not certify a shipper's determination of whether a material is a hazardous material. However, based on the information and test results you included in your letter, it is the opinion of this Office that your pine-derived biocarbon would not be considered a Division 4.2 self-heating material when transported within the United States. If your product does not meet any other hazard class as defined in 49 CFR Part 173, and is not a hazardous substance, hazardous waste, or marine pollutant, it is not subject to the HMR. Please note that international regulations may classify your material differently.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.22 173.124(b)(2)