Charcoal Briquette Products as a Consumer Commodity
Pipeline and Hazardous Materials Safety Administration · Nov 3, 2006 · Reference No. 06-0232
Interprets: 49 CFR § 173.151
Reggie’s quick take
Someone asked whether charcoal briquettes can be shipped as "Consumer commodity" under the ORM-D classification. The agency said yes under § 173.151(c), as long as each package weighs no more than 30 kg (66 lbs) gross and the briquettes, as packaged, meet the definition of a consumer commodity in § 171.8.
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 response to your letter dated October 10, 2006, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to hazardous materials authorized to be transported under the proper shipping name "Consumer commodity". Specifically, you ask whether your charcoal briquette product may be transported as "Consumer Commodity" ORM-D.
Under § 173.151(c), charcoal briquettes may be renamed "Consumer commodity" and reclassed as "ORM-D" provided each package does not exceed 30 kg (66 lbs) gross weight and the briquettes, as packaged, meet the definitions of a consumer commodity as specified in § 171.8.
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.