Use of UN Model Regulations Label

This responds to your October 21, 2013 e-mail to our Approvals and Permits Division regarding the labeling of packages under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your request was forwarded to this Office for a response. In your e-mail, you ask whether a Division 1.4S label with the text “Explosives” may be displayed on a package of small arms ammunition transported to or within the United States.

The answer is yes. Though the label you provide does not conform to the design requirements of the HMR, it is authorized by § 172.407(f). Section 172.407(f) authorizes, except for materials poisonous by inhalation, a label conforming to the United Nations Recommendations on the Transport of Dangerous Goods (UN Model Regulations). Further, it is the opinion of this Office that the label you provide in your letter would not be prohibited under 5.2.2.2.1.5 of the United Nations Model Regulations and may be displayed on a package of cartridges, small arms transported to, from or within the United States.

I trust this information is helpful. Please contact us if we can be of further assistance.