PHMSA letter of interpretation

Proper Shipping Names for Diesel Fuel Mixed with Vegetable and Animal Oils

Pipeline and Hazardous Materials Safety Administration · Jul 31, 2006 · Reference No. 06-0122

PHMSA says to use caution with this letter. On March 7, 2013 PHMSA published a Final Rule, HM-219, which removed the entry NA1203 Gasohol from the hazardous materials table.

Reggie’s quick take

Someone asked which shipping names fit fuel oil or diesel blended with vegetable and animal oils. A mixture must use the hazardous material's proper shipping name plus "solution" or "mixture," not separate constituent names. For 98% fuel oil or diesel with 2% of these oils, use "Diesel fuel solution," NA1993 or UN1202, or "Fuel oil solution," NA1993. For 80% fuel oil with 20% of these oils, use "Fuel oil solution," NA1993, or "Flammable liquid, n.o.s. (fuel oil solution)," UN1993.

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 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding proper shipping names for diesel fuel and fuel oils mixed with vegetable and animal oils, and gasoline mixed with denatured ethanol. The first product (B-2) is 98% fuel oil/diesel fuel blended with 2% vegetable and animal oils. The second product (B-20) is 80% fuel oil blended with 20% vegetable and animal oils. The third product is gasoline blended with at least 10% denatured ethanol. You state that data indicates the fuel oils blended with vegetable and animal oils have flash points meeting Class 3 (flammable) or combustible liquid definitions under the HMR. You also state that the shipping papers for these materials do not indicate that the material is mixed, rather, they show the materials listed separately. You ask which shipping names are most appropriate for these products.

A hazardous material mixed with a non-hazardous material must be described using the proper shipping name of the hazardous material and the qualifying word "mixture" or "solution," as appropriate, unless any of the provisions in § 172.101(c)(10)(i)(A) through (F) apply. Therefore, the most appropriate proper shipping names for the first product (B-2) are "Diesel fuel solution," NA1993, "Diesel fuel solution," UN1202, or "Fuel oil solution," NA 1993, as appropriate. The most appropriate proper shipping names for the second product (B-20) are "Fuel oil solution," NA 1993 or "Flammable liquid, n.o.s. (fuel oil solution)," UN1993, as appropriate. A material that is a mixture or solution must be indicated on the shipping paper with its appropriate proper shipping name and may not have its constituents or commercial names listed separately in lieu of the proper shipping name. Such information may, however, be indicated following the basic description.

Currently, the most appropriate proper shipping name for gasoline mixed with not more than 10% alcohol is "Gasohol," NA1203 or "Flammable liquid, n.o.s. (contains gasoline with 10% denatured alcohol)," UN1993. The proper shipping name "Gasoline," UN1203 would be appropriately assigned to gasoline that is not mixed with other hazardous materials.

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.