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Interpretation Response #21-0021

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

Interpretation Response Details

Response Publish Date:

Company Name: XPO Logistics – Supply Chain

Individual Name: Erin Sineath

Location State: NC Country: US

View the Interpretation Document

Response text:

April 1, 2021

Erin Sineath
Global Manager of Dangerous Goods
XPO Logistics – Supply Chain
4043 Piedmont Parkway
High Point, NC  27265

Reference No. 21-0021

Dear Ms. Sineath:

This letter is in response to your March 4, 2021, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the definition of a "different packaging." Specifically, you indicate that closure instructions for a UN Specification 4G (fiberboard) packaging require the use of “3/16-inch Anti-Static Bubble wrap” for assembly. You ask whether it would be permissible to purchase a bubble wrap from another vender, as long as the same design specifications have been met.

The answer is yes. In accordance with § 178.601(c)(4), "a different packaging is one that differs (i.e., is not identical) from a previously produced packaging in structural design, size, material of construction, wall thickness or manner of construction." Therefore, having the bubble wrap manufactured by a different person does not automatically constitute a different packaging. However, please note that if the bubble wrap differs in design specification, it would constitute a different packaging.

I hope this information is helpful. Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
178.601 General requirements