Interpretation Response #26-0008
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: MSC Mediterranean Shipping Company (USA) Inc.
Individual Name: Mr. Scott Higman
Location State: SC Country: US
View the Interpretation Document
Response text:
January 22, 2026
Mr. Scott Higman
MSC Mediterranean Shipping Company (USA) Inc.
700 Watermark Blvd.
Mt. Pleasant, SC 29464
Reference No. 26-0008
Dear Mr. Higman:
This is in response to your January 15, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of unpackaged vehicles in cargo transport units (CTUs) under the International Maritime Dangerous Goods (IMDG) Code. Specifically, you ask whether unpackaged vehicles shipped inside of CTUs require placarding when offered for transport in accordance with special provision 962 of Amendment 42-24 of the IMDG Code.
The answer to your question is no. Special provision 962 of the IMDG Code addresses when marking, labeling, and placarding requirements apply to packaged vehicles, and excludes unpackaged vehicles from these requirements. As you note in your email, the next amendment to the IMDG Code—i.e., Amendment 43-26, applicable on January 1, 2028—once adopted will require placarding for all vehicles in CTUs whether packaged or unpackaged. Amendments 42-24 and 43-26 to the IMDG Code may be considered by PHMSA for incorporation by reference in a future harmonization rulemaking. We note that permissive placarding is authorized by both the currently effective HMR and the currently effective IMDG Code.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Matthew Nickels
Acting Director, Standards & Rulemaking Division
Office of Hazardous Materials Safety
171.22