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Interpretation Response #01-0051 ([Zhen Hua Trading Limited] [Mr. Charles Ho])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Zhen Hua Trading Limited

Individual Name: Mr. Charles Ho

Country: HK

View the Interpretation Document

Response text:

SEP 20, 2001


Mr. Charles Ho                      Ref. No. 01-0051

Senior Manager

Zhen Hua Trading Limited

Room 2003, 20/F, C. C. Wu Building

302-308 Hennessy Road

Wanchai, Hong Kong

Dear Mr. Ho:

This responds to your letter regarding the classification of "wood charcoal" as a dangerous good under the u.S. Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and your plans to export this product to the U.S.

Under the HMR, it is the shipper's responsibility to determine whether a material meets the definition of a hazard class or is not subject to the regulations. Such determinations are not normally performed by this office. We will, however, provide assistance when possible, in the classification of a material.

Your letter did not describe the composition or physical form of the wood charcoal. Wood charcoal may meet the definition of a Division 4.2, spontaneously combustible material, if, after testing in accordance with the UN Manual Tests and Criteria (extract enclosed) it is determined the charcoal meets the hazard class criteria. However, if the material does not meet the definition of Division 4.2 or any other hazard class or division in the HMR, the material would not be subject to the HMR.

For information regarding trade with the U.S., we suggest that you contact the United States Department of Commerce's Trade information Center at or the International Trade Administration at 1-800-USA-TRADE.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



John A. Gale

   Regulations Specialist

   Office of Hazardous Materials Standards



Regulation Sections

Section Subject
171.12 North American Shipments