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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #23-0094

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

Interpretation Response Details

Response Publish Date:

Company Name: DCMA-TDLTC

Individual Name: Douglas Connell

Location State: OH Country: US

View the Interpretation Document

Response text:

January 12, 2024

Douglas Connell
1725 Van Patton Drive
Building 30
Wright-Patterson AFB, OH  45433

Reference No. 23-0094

Dear Mr. Connell:

This letter is in response to your October 26, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packages (i.e., boxes) of "UN1263, Paint (including paint, lacquer, enamel, stain, shellac solutions, varnish, polish, liquid filler and liquid lacquer base), 3, PG III" that are palletized and listed on a shipping paper. You state a carrier has informed you that a shipping paper must include the number of boxes containing "UN1263" on the bill of lading (e.g., shipping paper). You are uncertain of the carrier's understanding and reference a letter of interpretation (Reference No. 09 0158), which you believe has broader applicability and allows the use of “pallet” or "PLT" as the description of the type of package on a shipping paper. Specifically, you ask whether in your scenario the shipping paper must include the number of boxes along with the number of pallets in accordance with § 172.202(a)(7). You also provided a copy of the shipping paper in question for review.

Based on the information and copy of the shipping paper you provided, the shipping paper must include the type of package used to contain the "UN1263" material. A pallet ("PLT") is not an acceptable package type for this material. A skid or pallet is commonly considered an overpack and not a package type in accordance with the HMR (see § 171.8).

In accordance with § 172.202(a)(7) of the HMR, the number and type of packages must be indicated on a shipping paper (e.g., 12 boxes). Therefore, the number and type of packages for “UN1263” for each pallet must be documented on a shipping paper; however, the number of pallets does not need to be indicated. For example, an entry on a shipping paper for "UN1263" may be listed as:

  • UN1263, Paint, 3, PG III, 12 boxes, 271 lbs.

Regarding Reference No. 09-0158, it addresses a unique packaging authorization applicable to wet batteries ("UN2795"). Specifically, § 173.159(d)(1) authorizes electric storage batteries secured on skids or pallets as an authorized non-specification packaging. In that scenario, it is acceptable for the person to indicate "1 skid" or "1 pallet" as the package type on the shipping paper because of the requirements found in § 173.159(d)(1).

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

171.8, 172.202(a)(7), 173.159(d)(1)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.202 Description of hazardous material on shipping papers
173.159 Batteries, wet