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Interpretation Response #23-0055

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

Interpretation Response Details

Response Publish Date:

Company Name: Amazon Inc.

Individual Name: Mr. Josh Galvarino

Location State: TN Country: US

View the Interpretation Document

Response text:

April 19, 2024

Mr. Josh Galvarino 
Senior Risk Manager
WW DG Regulatory Engagement
Amazon Inc.
1010 Church St.
Nashville, TN 37203

Reference No. 23-0055

Dear Mr. Galvarino:

This letter is in response to your June 20, 2023, letter and subsequent conversations with members of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of "infinity bags"1 —as a carrier—to consolidate packages and whether the "overpack" requirements specified in §§ 173.25(a)(2), 173.185(c)(1)(vi), and 173.185(c)(3)(iii) apply in such instances. You describe several scenarios in which "infinity bags" are used to consolidate packages by Amazon employees (or employees directly contracted to work for Amazon) working at warehouses, intermediate handling facilities, sorting centers, distribution points, etc.—i.e., all within the transportation chain that Amazon operates within its network of facilities, vehicles, and airline. You state that Amazon does not transfer the "infinity bags" to another carrier, airline, or third-party, and uses these consolidating "infinity bags" solely within its network as a carrier. You ask whether the "infinity bags" described in your letter are considered overpacks as defined by § 171.8.

1 In accordance with 49 CFR § 105.30, Amazon requested the "infinity bag" photographs contained within the interpretation request be treated as confidential to prevent any trade secret damage relating to design and construction of the bag.

The answer is no. As defined in § 171.8 of the HMR, an overpack "means an enclosure that is used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages." The intent of the words "used by a single consignor" are to differentiate between a shipper-prepared overpack and an enclosure or handling device utilized by a carrier to consolidate goods for convenience of the carrier and onward movement. Such consolidations are not considered overpacks as defined by § 171.8. As such, when Amazon acts in a carrier capacity and uses "infinity bags" to consolidate packages as a means of convenience for carriage, such bags are not considered overpacks as defined by § 171.8. However, if offered for transportation to a third-party the overpack definition and associated requirements would apply.

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


Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

171.8, 173.25(a)(2), 173.185(c)(1)(vi), and 173.185(c)(3)(iii)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.185 Lithium cells and batteries
173.25 Authorized packagings and overpacks