Cartridges Small Arms Internationally
Pipeline and Hazardous Materials Safety Administration · Nov 30, 2005 · Reference No. 05-0232
Interprets: 49 CFR § 172.101, 49 CFR § 173.56(h)
Reggie’s quick take
A manufacturer asked whether small arms cartridges it makes and classes under § 173.56(h) can be labeled as Cartridges, small arms, 1.4S, UN 0012, for both domestic and international shipping. PHMSA said yes. Cartridges that meet all the criteria of § 173.56(h) can get the 1.4S code from the manufacturer, with no special permit needed. Other countries may not accept that classification, though. They can ask for more testing or a written concurrence from their competent authority. PHMSA will provide that concurrence if the shipper asks for it.
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 September 20, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if cartridges, small arms manufactured and classed by your company under the provisions of § 173.56(h), may be classed as Cartridges, small arms, 1.4S, UN 0012 for domestic and international transportation.
The answer is yes. Cartridges, small arms meeting all the criteria of § 173.56(h) may be assigned a classification code of 1.4S by the manufacturer, for both domestic and international transportation without obtaining an approval from the Office of Hazardous Materials Special Permits and Approvals. You should know however that a country may choose not accept a classification assigned by another country or the manufacturer. In such cases, a country may require further examination and testing of Class 1 materials such as Cartridges, small arms, or a written concurrence from the Competent Authority. The Pipeline and Hazardous Materials Safety Administration will provide such concurrence upon request of the shipper, if needed.
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.