Letters "USA" to Indicate "the State Authorizing Allocation of the Mark"

This is in response to your letter of April 6, 1992, which requested clarification of our policy regarding the use of the letters "USA" to indicate "the State authorizing allocation of the mark" in connection with the marking of UN packages. This reply applies to:

a) Non-bulk packages certified and marked as UN packages pursuant to the provisions of 49 CFR Part 178, the United Nations (UN) Recommendations on the Transport of Dangerous Goods, the International Maritime Organization (IMO) International Maritime Dangerous Goods (IMDG) Code or the International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air; and

b) Intermediate Bulk Containers (IBCs) certified and marked as UN packages pursuant to the provisions of the UN Recommendations or the IMO IMDG Code.

We concur with your understanding of the limitations associated with use of the letters "USA" in connection with UN markings on packages, and the rationale upon which your understanding is based. The letters "USA" may only be marked on packages to indicate "the State authorizing allocation of the mark" when the packaging has been manufactured and marked in the United States (see 49 CFR 178.503(a)(7)). For purposes of these requirements, the United States includes only the fifty States, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, American Samoa, and Guam.