Interpretation Response #26-0037

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

Interpretation Response Details

Response Publish Date: 06/25/2026

Company Name: Acme Corrugated Box Co., Inc.

Individual Name: Jeff Bittner

Location State: PA Country: US

View the Interpretation Document

Response text:

June 25, 2026

Mr. Jeff Bittner
Technical Sales Representative
Acme Corrugated Box Co., Inc.
2700 Turnpike Drive
Hatboro, PA  19040

Reference No. 26-0037

Dear Mr. Bittner:

This is in response to your January 21, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to United Nations (UN) specification packaging. In your email, you describe a scenario involving corrugated boxes manufactured by your company. You state that during recent recertification testing, the testing laboratory identified that the most recent production samples utilized a 42-pound middle liner instead of the 26-pound liner specified in the previous test report. You further state that these upgraded boxes—reflecting the new paper combination—were subsequently tested successfully as a UN standard package, and a new test report was issued. Specifically, you request written acknowledgment that your boxes are approved for use as a UN specification packaging.

Please note that PHMSA does not explicitly "approve" standard UN specification packagings. In accordance with § 178.601(b), "[i]t is the responsibility of the packaging manufacturer to assure that each package is capable of passing the prescribed tests." When a change is made to a packaging design, such as upgrading the middle liner from 26-pound to 42-pound, it may constitute a new or different "design type" under § 178.601(c)(4), which requires design qualification testing. Because the test lab successfully tested the new design type containing the 42-pound liner and documented it in the provided January 7, 2026 test report, the design qualification requirements appear to have been met.

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

Sincerely,

Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

178.601(b) 178.601(c)(4)

Regulation Sections