Dual Markings on Cartridges for Small Arms
Pipeline and Hazardous Materials Safety Administration · Apr 11, 2003 · Reference No. 03-0076
Interprets: 49 CFR § 172.301
Reggie’s quick take
Someone asked whether small arms cartridges (UN0012, Division 1.4S) that have been reclassed as ORM-D for domestic shipment may carry both the international and domestic markings on the same package. PHMSA said yes. For international transport, each package is marked "Cartridges, small arms, UN0012, II" and labeled 1.4S. For domestic U.S. transport, the same package is marked "Cartridges, small arms, ORM-D." This is allowed under § 173.63(b) when the cartridges are packaged as that section requires, under § 173.63(b)(2). The letter also says smokeless powder reclassed under § 173.171 may carry dual markings, but that answer only repeats the first one.
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 February 26, 2003, regarding marking and labeling requirements and exceptions for Cartridges, small arms and Smokeless power under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked does the HMR allow a shipper to offer Cartridges, small arms, UN0012, that have been reclassed and offered for transportation as Cartridges, small arms, ORM-D, to display dual markings? Your questions are paraphrased and answered as follows:
Q1. Does the HMR allow a shipment of Cartridges, small arms, UN0012, II, reclassed as Cartridges, small arms, ORM-D, to display dual markings?
A1. The answer is yes. These packages may contain multiple (international and domestic U.S.) markings and labels. For international transport, each package of cartridges would be marked "Cartridges, small arms, UN0012, II", and labeled "1.4S", and for domestic U.S. transport, each package would be marked "Cartridges, small arms, ORM-D." As prescribed in § 173.63(b), small arms cartridges which have been classed as a Division 1.4S explosive may be reclassed, offered for transportation, and transported as ORM-D material when packaged in accordance with § 173.63(b)(2).
Q2. In accordance with § 173.171 of the HMR, can shipments of "Power smokeless, 1.3, UN0161, I", reclassed in Division 4.1 (Smokeless power for small arms, 4.1, NA3178, I), display dual markings?
A2. The answer is yes. See answer A1.
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.