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Interpretation Response #10-0042 ([Toyota Motor Sales, USA, Inc.] [Mr. Wieten])

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

Interpretation Response Details

Response Publish Date:

Company Name: Toyota Motor Sales, USA, Inc.

Individual Name: Mr. Wieten

Location State: CA Country: US

View the Interpretation Document

Response text:

October 13, 2010




Mr. Dan Wieten

Environmental Hazmat & Safety Group

Legal and Corporate Responsibility Department

Toyota Motor Sales, USA, Inc.

19001 South Western Avenue

Torrance, CA 90501

Reference No. 10-0042

Dear Mr. Wieten:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to labeling requirements. Specifically, you state that you receive packages from overseas that may stay in inventory for long periods of time and reoffer the packages (in this case, packages containing batteries) into transportation. The labels on the packages display the word "Corrosive" in both English and Japanese. You refer to interpretation letter, Reference No. 98-0235, and state that your understanding of the letter is that the packages may be reoffered into transportation with the Japanese wording on the labels. You ask whether your understanding is correct.

Your understanding is correct. Except for materials poisonous by inhalation, labels conforming to specifications in the UN Recommendations on the Transport of Dangerous Goods may be used in place of the corresponding label under the HMR (see §§ 172.401(c) and 172.407(f)). These labels may contain text indicating the hazard in the language of the country from which a shipment originates and may continue to be displayed when they are reoffered into transportation, regardless of the length of time the packages are held in inventory. With respect to English wording on labels, for Classes 1, 2, 3, 4, 5, 6, and 8 hazardous materials (see § 172.405(a)), text indicating a hazard (for example, "Corrosive") is not required on a primary or subsidiary label, but it too may continue to be displayed when the package is being reoffered into transportation.

I hope this information is helpful. Please contact this office should you have additional questions.


T. Glenn Foster

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.401(c), 172.407(f), 172.405(a)

Regulation Sections

Section Subject
172.401 Prohibited labeling
172.407 Label specifications