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New Requirements
New Regulatory Requirements

Harmonization with International Standards; Class 9 label amendment - Docket HM-218F

In an attempt to harmonize and align with international standards, the DOT has amended the 49CFR regulations regarding the Class 9 diamond label. Effective October 1, 2014 with the publication of the HM-218F final rule, the Class 9 diamond label is changing.

CLASS 9 label without black horizontal must be used beginning October 1, 2014.
CLASS 9 without black horizontal line before October 1, 2014


CLASS 9 label with black horizontal line before October 1, 2014.
CLASS 9 with black horizontal line before October 1, 2014


DOT-SP 9275 Update:

On March 18, 2014, PHMSA published Final Rule HM233-C. Included in this rulemaking is language {49CFR 173.150 (g)}, which integrates DOT Special Permit 9275 into the regulations. With this change, shippers are no longer required to request party status to use this Special Permit to ship small quantities of products containing ethyl alcohol. The new rule authorizes transportation of liquids and solids containing ethyl alcohol and exempts them from the provisions of the HMR, including the requirement to mark the package "contains ethyl alcohol".

This rule applies to limited quantities of retail products containing not more than 70% of ethyl alcohol not exceeding 8 fluid ounces in glass inner containers and not exceeding 16 fluid ounces for non-glass inner containers. Packages containing inner packagings exceeding these quantities (up to 1 gallon) shipped under this section require the marking "contains ethyl alcohol" on the outer packaging. For transportation by aircraft no outer package is permitted which contains inner packaging exceeding 16oz liquid or 1 pound solid.

This rule became effective April 17, 2014.

Harmonization with International Standards; Seeks Further Input on Domestic Transport of Lithium Batteries - Docket HM-215L

HM-215L states - the quantity limit for these entries should be based on the weight of the battery or batteries and not the weight of the battery or batteries plus the packaging (i.e., the package). A 49CFR shipping paper no longer requires, nor should it show a "G" for gross as of January 1, 2014 for the following materials.
  • UN3028 Batteries, dry, containing potassium hydroxide solid, electric, storage
  • UN2794 Batteries, wet, filled with acid, electric storage
  • UN2795 Batteries, wet, filled with alkali, electric storage
  • UN3468 Hydrogen in a metal hydride storage system or Hydrogen in a metal hydride storage system contained in equipment or Hydrogen in a metal hydride storage system packed with equipment
  • UN3090 Lithium battery
  • UN3091 Lithium batteries packed with equipment

172.301 General marking requirements for non-bulk packagings.

(a) Proper shipping name and identification number.
(1) Except as otherwise provided by this subchapter, each person who offers a hazardous material for transportation in a non-bulk packaging must mark the package with the proper shipping name and identification number(preceded by "UN", "NA" or "ID", as appropriate) for the material as shown in the 172.101 Hazardous Material Table. The identification number marking preceded by "UN", "NA" or "ID" as appropriate must be marked in characters at least 12mm (0.47 inches) high. Packages with a maximum capacity of 30 liters (8 gallons) or less, 30 kg (66 pounds) maximum net mass, or cylinders with water capacity of 60 liters (16 gallons) or less must be marked with characters at least 6mm (0.24 inches) high. Packages with a maximum capacity of 5 liters (1.32 gallons) or 5 kg (11 pounds) or less must be marked in a size appropriate for the size of the package.
(i) Transitional exception. For domestic transportation, until January 1, 2017, the identification number markings are not subject to the minimum size requirements specified in paragraph this (a)(1).

Lighters - Docket HM - 237

Effective January 1, 2012, all shipping papers and packages containing Lighters must bear an approval number beginning with the prefix "LAA-" indicating compliance with HM - 237.  Shipping papers showing approval numbers beginning with the prefix "T" will no longer be accepted as these previously issued approvals are no longer valid.

As a reminder, UPS does not permit the use of the exception (49 CFR 173.308) for cigarette lighters or similar devices. To be transported in the UPS system, these devices must be fully declared. They require shipping papers, proper packaging, marking, and labeling.

Elimination of ORM-D Classification

In an attempt to harmonize and align with international standards, the DOT has amended the 49CFR regulations regarding the ORM-D classification. Effective January 19, 2011, with the publication of the HM-215K final rule, the hazard class of ORM-D is being eliminated.  Those materials may still be shipped classified as a limited quantity (ltd qty). In conjunction with ORM-D hazard class elimination in HM-215K, limited quantity ground shipments will no longer require shipping papers when prepared under the new rule.  This includes those materials previously classed as ltd qty that required shipping papers via ground transport. 

There is a transition period for shippers to comply with the new classification, marking and labeling requirements. Until December 31, 2020 a limited quantity package containing a consumer commodity as defined in 171.8 may be reclassed as ORM-D, or until December 31, 2012 for ORM-D-Air material. UPS began accepting materials with the new markings effective April 1, 2011. See examples of the new ground and air limited quantity markings below that will be replacing the ORM-D and ORM-D-Air markings.  
Air ltd qty marking

Air ltd qty marking

Marcado para cant ltda terrestre

Ground ltd qty marking

It is the shipper's responsibility to know the regulations, and to properly classify, package, label, and mark their hazmat shipments.

*Note: To be in compliance with TDG, Standard (ground) Ltd Qty shipments to Canada prepared under HM-215K require the verbiage 'Limited quantity' or 'Ltd qty' to also be marked on the carton.
Emergency Response Registrant Information - Docket HM-206F

Beginning October 1, 2010, a new U.S. Department of Transportation regulation will require printing Emergency Response Registrant (ERR) information on shipping papers for hazardous materials shipments sent to or from all states in the United States and Puerto Rico. The ERR information must be associated with the Emergency Contact Number. This information must also be transmitted electronically to UPS by your shipping system.

Failure to comply with these new requirements may result in government fines up to $50,000 per package. It is critical that all UPS hazardous materials shippers take the necessary actions to ensure compliance. Hazardous materials shipments that do not comply will encounter service delays. To determine whether the new ERR information requirement applies to you, select the U.S. Department of Transportation link below. Note: You will have to search for Docket HM-206F at:

If the requirement does apply to your shipments and you're using an earlier version of UPS WorldShip, you must upgrade your software to version 12.0 by downloading or ordering a CD. UPS WorldShip 2010 version 12.0 users will automatically see the new ERR information field applied as part of electronic updates scheduled for third quarter 2010.

If you are using an external source for your Dangerous Goods Chemical Record Data you will need to add a field called ER_Registrant to your external data source. Contact your provider to ensure timely updates to meet this requirement.
IATA Packing Instruction Change
The changes to the IATA Packing Instructions effective January 1, 2011 are reflected in the 52nd Edition of the IATA DGR 4.2 List of Dangerous Goods. Appendix H references the 51st Edition Packing Instructions. The ICAO Dangerous Goods Panel has agreed to a three month transition period to allow shippers to take care of any in-stock dangerous goods shipments prepared using the old Packing Instructions. Per the IATA 2011 Packing Instruction Transition Guidance document (dated 26 November 2010) "When the transitional provisions are being used, the Shipper's Declaration must show the packing instruction number applicable in the 51st edition of the DGR. In this instance the date on the Shipper's Declaration should be the date the document was prepared, i.e. a date up to and including 31 March 2011." It is the shipper's responsibility to ensure their dangerous goods meet all of the current regulatory requirements. UPS will accept dangerous goods prepared using the IATA 51st Edition Packing Instructions through March 31, 2011.
Organic Peroxide Label
Effective January 1, 2011 the solid yellow diamond label for class 5.2 Organic Peroxide materials is obsolete. The required diamond is as shown.
Organic Peroxide Label


IATA Limited Quantities Mark
When using the IATA DGR, packages of dangerous goods shipped under the Limited Quantity provisions of Subsection 2.8, must be marked with the Limited Quantities mark as shown in Figure 7.1.A.

49 CFR 173.4 Small Quantity Exception Changes - Mandatory January 2010

Effective January 1, 2010 complete mandatory requirements for Small Quantity Exceptions under 49 CFR are found online at D.O.T.'s eCFR at:

49 CFR 173.4 - Small quantities for highway and rail
  • Must be marked with new statement of: "This package conforms to 49 CFR 173.4 for domestic highway or rail transport only"

49 CFR 173.4a - Excepted quantities

  • Applicable marking for domestic air (or surface) and international air EQ packages meeting passenger aircraft provisions

49 CFR 173.4b - De minimis Exceptions
  • Material must meet all provisions set forth in regulations to qualify
Lithium Battery Proposed Regulatory Change

Lithium Battery Regulation Change
Effective immediately, in accordance with the D.O.T's Federal Register posting of August 25, 2009 (Docket No. PHMSA - 2009 - 0253; Notice No. 09-4) Notice of Approval: Lithium Battery Shipping Descriptions, UPS will permit the international lithium battery descriptions for the domestic transportation of lithium batteries.

Effective October 1, 2008, medium lithium batteries become fully regulated for air shipment in the U.S. Department of Transportation's (DOT) Hazardous Materials Regulations. Lithium batteries are considered a hazardous material because they can overheat and ignite in certain conditions and, once ignited, can be especially difficult to extinguish.

The new regulation will require packages containing medium lithium batteries, and offered for air transport, to be properly packaged, marked, and labeled as Hazardous Materials and accompanied by shipping papers. Otherwise, the shipment may be delayed, or significant U.S. DOT fines could apply. U.S. DOT has the ability to issue fines and penalties as high as $110,000 per violation for non-compliance.

Common examples of medium lithium batteries include:

  • Power supplies for high-intensity, long-life portable lighting, such as diving lamps
  • Some extended-life batteries for laptops
  • Larger batteries for high-level video cameras (used by film and news crews)
  • Long-life communications power supplies  

These changes apply to shipments of loose medium lithium batteries as well as medium batteries contained inside of equipment, or packed with equipment.

Beginning October 1, 2008:

  • Air shipments of medium lithium batteries must display the "Cargo Aircraft Only" label if the package exceeds 5 kg (11 pounds). UPS accepts hazardous materials only from shippers with a contract or agreement for such service.
  • Ground shipments of medium lithium batteries must be marked as follows:

    • "LITHIUM BATTERIES - FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL."

    • Text size for the above marking depends on the size of the package:
      • Gross weight of 30 kg (66 LB) or less - letters at least 6 mm (0.25 inch) high
      • Gross weight over 30 kg (66 LB) - letters at least 12 mm (0.5 inch) high

    • If there are more than 12 batteries in a package, DOT requires an additional damage warning both on the package and in an accompanying document that would be affixed to the package in a resealable envelope. The DOT-required warning and document both advise handlers that the package contains lithium batteries and that certain safety measures are required if it is damaged. 

For full information about these changes, shippers should review the applicable U.S. DOT Final Rule. Shippers may also contact the U.S. DOT Pipeline and Hazardous Materials Safety Administration's Hazmat Info-Line at 1-800-467-4922.
Air Package Limitations
Packages containing any material (or combination of materials) listed below must not exceed a combined net weight of 25 kg of the listed materials when offered for air transport. Overpacks of packages containing any material (or combination of materials) listed below must not exceed a combined net weight of 25 kg (of the listed materials) when offered for air transport.

  • Class 3, PG I and II
  • Div 4.1, any PG
  • Div 4.3, any PG
  • Div 6.1, PG I and II
  • Class 8, PG I and II

If you have any questions about shipping hazardous materials with UPS, please call the Hazardous Materials Support Center at 1-800-554-9964.

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