Clarification on Materials of Trade (MOTs)
Pipeline and Hazardous Materials Safety Administration · Jun 28, 2000 · Reference No. 00-0141
Interprets: 49 CFR § 173.6
Reggie’s quick take
A company's research staff asked whether an employee could drive lab samples to an outside analytical lab and bring them back under the Materials of Trade exception. PHMSA said yes, as long as the employee is in private carriage and the trip directly supports the company's business. The answer assumes the § 173.6 requirements are met. The letter does not say what kinds of samples were involved.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your letter of May 2, 2000, requesting clarification on the requirements for Materials of Trade (MOTs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -180). You provide the following scenario and ask whether the MOTs exception may be applied.
From time to time "samples" must be transported to an independent analytical laboratory for various analyses. Could a Merichem Research Center employee transport the samples to the laboratory? After analyses are completed, could a Merichern employee transport the samples back to the Merichem Research Center? All requirements in § 173.6 are met.
The answer is yes. A Merichern Research Center employee may transport samples to and from a laboratory in direct support of their business when in private carriage.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.