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Interpretation Response #21-0034

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Keith Baecht

Country: US

View the Interpretation Document

Response text:

April 28, 2021

Keith Baecht
Winchester Ammunition

Reference No. 21-0034

Dear Mr. Baecht:

This letter is in response to your March 24, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of an explosive. Specifically, you indicate that you are taking the primer out of a centerfire rifle cartridge and that the product has:

  • A projectile loaded in the end of the shell case;
  • Powder inside the shell case; and
  • An inert primer.

You ask how to classify this variation of an explosive that would otherwise be classified and described as UN0012, Cartridges, small arms, 1.4S, in accordance with § 173.56(h).

As required by § 173.56(a), the cartridge must be classified as a new explosive. In accordance with § 173.59, Cartridges, small arms means "[a]mmunition consisting of a cartridge case fitted with a center or rim fire primer and containing both a propelling charge and solid projectile(s). They are designed to be fired in weapons of caliber not larger than 19.1 mm. Shotgun cartridges of any caliber are included in this description. The term excludes: Cartridges, small arms, blank, and some military small arms cartridges listed under Cartridges for weapons, inert projectile." Based on the description in your email, the product would not meet this definition and thus, is not eligible for self-classification in accordance with § 173.56(h). Therefore, the product would need to be appropriately examined, classified, and approved in accordance with § 173.56(b) before being offered for transportation in commerce.

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

173.56(a), 173.56(b), 173.56(h)

Regulation Sections

Section Subject
173.56 New explosives-definition and procedures for classification and approval