Interpretation Response #25-0140
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: BASF Services Americas S.R.L.
Individual Name: Mr. Pablo Calabrese
View the Interpretation Document
Response text:
June 4, 2026
Mr. Pablo Calabrese
BASF Services Americas S.R.L.
Dr. Luis Bonavita 1266
11300 Montevideo, Uruguay
Reference No. 25-0140
Dear Mr. Calabrese:
This is in response to your October 29, 2025 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of proper shipping names intended for domestic use. Specifically, you ask whether there is a prohibition under the HMR or international standards on the use of the proper shipping name "NA3082, Other regulated substances, liquid, n.o.s." when a shipment originates from the United States and is intended for international transport. In addition, you state that the material is not regulated for transportation by the destination country.
When offered for transportation under the HMR, the answer is no, there is no prohibition against the use of an NA description for an international shipment. In accordance with § 172.101(e), identification numbers prefixed with "NA" are domestic descriptions not recognized in international standards, such as the International Maritime Organization (IMO)'s International Maritime Dangerous Goods (IMDG) Code or International Civil Aviation Organization (ICAO) Technical Instructions. Therefore, carriers accepting shipments transported under those international standards may require the use of the "UN3082" entry. As you stated in your letter, § 172.101 Hazardous Materials Table (HMT) entries with the letter "D" in Column (1) may be inappropriate for international transportation under the provisions of international regulations (e.g., IMO, ICAO). Section 172.101(b)(3) authorizes an alternate proper shipping name when either domestic or international transportation is involved.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Arthur Pollack
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.101(b)(3) 172.101(e)
Regulation Sections
| Section | Subject |
|---|---|
| 172.101 | Purpose and use of hazardous materials table |