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Interpretation Response #01-0068 ([LR International Cosmetic & Marketing GmbH & Co.] [Mr. Michael Miska])

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

Interpretation Response Details

Response Publish Date:

Company Name: LR International Cosmetic & Marketing GmbH & Co.

Individual Name: Mr. Michael Miska

Country: DE

View the Interpretation Document

Response text:

MAY 2, 2001


Mr. Michael Miska                     Ref. No. 01-0068

LR International Cosmetic &

Marketing GmbH & Co.

KG Gersteinstr. 7

59227 Ahlen


Dear Mr. Miska:

This responds to your letter regarding consumer commodity reclassification and emergency response telephone number requirements under the U.S. Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the ICAD Technical Instructions for the Safe Transport of Dangerous Goods By Air. Your questions are paraphrased and answered as follows:

Q1. Our company intends to export Perfumery products, Class 3, UN1266, Packing Group II, to the U.S. Under the HMR, may this product be reclassed ORM-D and renamed Consumer commodity?

A1. The answer is yes. Provided the perfumery products meet the definition of a consumer commodity in § 171.8, you may package them under the limited quantity provisions prescribed in § 173.150(b) and are eligible to rename them under the exceptions for consumer commodities in § 173.150{c).

Q2. May we reclassify and rename our product "Consumer commodity" under the read Technical Instructions?

A2. The answer is yes. Provided the consumer commodity conforms to Special Provision A112 and is packaged according to Packing Instruction 910 of the ICAO Technical Instructions, the proper description would be "Consumer commodity, Class 9".

Q3. Do Consumer commodities, ORM-D or Class 9, require a emergency response telephone number to be included on a shipping paper?

A3. The answer is no. Under § 172.604{b) (2) of the HMR and State Variation US12 of the 2001-2002 ICAO Technical Instructions, a material properly described as a Consumer commodity is excepted from the emergency response telephone number requirements.

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


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.604 Emergency response telephone number