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Interpretation Response #25-0060

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

Interpretation Response Details

Response Publish Date:

Company Name: Global Industrial Packaging

Individual Name: John Foryt

Location State: OH Country: US

View the Interpretation Document

Response text:

July 15, 2025

John Foryt
Director, Global Product Safety & Compliance 
Global Industrial Packaging
366 Greif Parkway
Delaware, Ohio 43015

Reference No. 25-0060

Dear Mr. Foryt:

This letter is in response to your May 1, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to markings on UN specification non-bulk performance-oriented packagings. Specifically, can a single UN symbol be used to meet the requirements in § 178.503(a)(1) when multiple (e.g., two or more) markings are included on a packaging.

No. In accordance with § 178.3(c), the HMR specifically states if more than one marking appears on a packaging, each marking must appear in its entirety. Thus, each marking string must include its own UN symbol or the letters "UN" as part of the marking string.

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

Sincerely,

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

§ 178.3(c), § 178.503(a)(1)

Regulation Sections