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Interpretation Response #98-0235 ([Toyota Motor Sales, U.S.A., Inc.] [Mr. Anthony P. Wilson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Toyota Motor Sales, U.S.A., Inc.

Individual Name: Mr. Anthony P. Wilson

Location State: CA Country: US

View the Interpretation Document

Response text:

SEP 1, 1998


Mr. Anthony P. Wilson                       Ref. No. 98-0235
Senior Logistics Supply Administrator
Mail Stop G-401
Toyota Motor Sales, U.S.A., Inc.
19001 South Western Avenue
Torrance, California 90509-2991

Dear Mr. Wilson:

This responds to your letter of August 10, 19 9 8, C o nce rning labeling requirements of the Hazardous Materials Regulations (H M R; 49 CFR Parts 171-180). Specifically, you ask if labels on shipments of auto parts you received from Japan comply with the HMR with regard to the text in English and Japanese and the background color.

Text on a label that indicates a hazard is not required by the HMR. However, it is permissible to include such text. Labels conforming to specifications in the UN Recommendations on the Transport of Dangerous Goods may be used in place of the corresponding label under the HMR (see § 1 72.40 7 (f) ) . These labels may contain text indicating the hazard in the language of the country from which a shipment originates.

Colors authorized for UN labels can be found in Chapter 13 of the Tenth Edition of the UN Recommendations (see section  13.  5.1) . While the UN Recommendations are tot as specific as the HMR concerning color tolerances for labels, they do include color pictures for each label authorized for international transportation. Shippers should compare actual labels with the pictures in section 13.5.1 to ascertain whether specific labels comply with the UN Recommendations.  With your letter, you enclosed two examples of the labels used by your Japanese shipper.  It is the opinion of this office that the olive-green label is not consistent with the color specification in the UN Recommendations; however, the darker green label does appear to comply with the UN standard.

I hope this satisfies your request. If you need additional assistance, do not hesitate to contact us.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.407 Label specifications