Interpretation Response #15-0239 ([Inmark Packaging] [Mr. Jay Johnson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Inmark Packaging
Individual Name: Mr. Jay Johnson
Location State: GA Country: US
View the Interpretation Document
Response text:
May 04, 2017
Mr. Jay Johnson, DGSA
Regulatory Compliance Manager
Inmark Packaging
675 Hartman Road, Suite 100
Austell, GA 30168
Reference No. 15-0239
Dear Mr. Johnson:
This letter is in response to your email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the manufacture of United Nations (UN) specification packaging. Specifically, you ask whether a specification packaging design may be tested and certified by a U.S. Department of Transportation (DOT) approved third party laboratory in the United States and physically manufactured and marked "USA" in Singapore for use in Asia. You further note that due to its inability to certify Division 6.2 (infectious substance) packaging designs, the competent authority of Singapore has stated it would recognize such packaging designs provided they are identical to those successfully tested and certified in the United States.
The answer is no. Marking is the final step in the packaging manufacturing process. If a packaging is marked in Singapore, it cannot be marked "USA" as the country of manufacture. If a packaging was sent to the United States and marked here, the "USA" mark is authorized.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division