Combustible Liquid
Pipeline and Hazardous Materials Safety Administration · Oct 5, 2001 · Reference No. 01-0239
Interprets: 49 CFR § 173.120
Reggie’s quick take
Someone asked whether a natural and artificial apple cinnamon flavor with a flash point of 70 C (158 F) is regulated under the Hazardous Materials Regulations. The agency said the shipper is responsible for classifying the material and that it generally does not do this itself. Under § 173.120, a liquid with a flash point between 60.5 C (141 F) and 93 C (200 F), which fits no other hazard class, is a combustible liquid. So this flavor is classed as a combustible liquid. In non-bulk packaging of 450 L or less, a combustible liquid is not subject to any HMR requirements, labeling included, unless it is also a hazardous waste, hazardous substance, or marine pollutant.
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 dated September 5, 2001, requesting clarification on whether your natural and artificial apple cinnamon flavor with a flash point of 70 C (158 F) is regulated under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Under § 173.22, it is the shipper's responsibility to properly classify a hazardous material. This office generally does not perform this function. Under § 173.120, combustible liquid is defined as a material with a flash point above 60.5 C (141 F) and below 93 C (200 F), and does not meet the definition of any other hazard class under the HMR. Therefore, in accordance with the HMR, your natural and artificial apple cinnamon flavor is classed as a combustible liquid. A combustible liquid in a non-bulk (450 L or less) packaging is not subject to any requirements under the HMR, including labeling, unless the material is a hazardous waste, hazardous substance or marine pollutant.
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.