Duplicate labeling provisions
Pipeline and Hazardous Materials Safety Administration · Jul 11, 2007 · Reference No. 07-0104
Interprets: 49 CFR § 172.406
Reggie’s quick take
A shipper asked whether it may put a duplicate label on a package when the package does not meet one of the conditions in § 172.406(e). PHMSA says yes. Duplicate labels are generally required only under the conditions in § 172.406(e), but nothing in the rules bars adding one anyway. If a shipper chooses a duplicate label, it does not also need a duplicate shipping name marking.
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 responds to your May 22, 2007 email requesting clarification of the duplicate labeling provisions of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you may apply a duplicate label if you do not meet one of the conditions listed in §172.406(e) of the HMR.
The answer is yes. Generally, duplicate labeling is not required on a package or containment device except under the conditions specified in § 172.406(e) (see § 172.406(a)(2)). However, nothing in the HMR prohibits the application of duplicate labels. Thus, you may apply duplicate labels to a package even where the conditions specified in § 172.406(e) are not met. If you elect to apply a duplicate label, it is not necessary to also apply a duplicate shipping name marking.
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.