Shipper's Certification on Shipping Paper
Pipeline and Hazardous Materials Safety Administration · Jun 28, 1995 · Reference No. 95-0106
Interprets: 49 CFR § 172.204(a)(2)
Reggie’s quick take
A company asked whether it could put its own shipper's certification on shipping papers, one that adds IMDG Code and DOT packaging language to the standard wording. PHMSA said no. Section 172.204(a)(2) requires the certification to be used as written, with only the mode of transportation added. The agency noted the standard wording comes from UN recommendations and that "applicable regulations" covers the HMR and the IMDG Code. It suggested a rulemaking petition under § 106.31 as the route for changing the wording.
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 dated April 27, 1995, concerning modification of the shipper's certification on shipping papers, applicable to both national and international hazardous materials shipments.
You developed the following certification and request that your company be allowed to place this statement on shipping documentation :
"This is to certify the contents of this consignment are fully and accurately described herein by proper shipping name and are classified, packaged, marked and labeled/placarded, and in all respects in proper condition for transport according to applicable international and national governmental regulations. When applicable, packaging of the container has been carried out in accordance with the provisions of the IMDG Code and DOT regulations."
The "certification" statement specified in § 172.204(a)(2) must be written as specified and may not be modified except as indicated to include the mode(s) of transportation. Thus, the certification shown above is unacceptable under the requirements in § 172.204(a)(2).
For your information, the certification in § 172.204(a)(2) includes language contained in the certification in Section 13.6.4 of the United Nations Recommendations on the Transport of Dangerous Goods. This wording is intended to facilitate the transport of hazardous materials in domestic or international commerce, or both. The phrase "applicable international and national governmental regulations", in the certification in § 172.204(a)(2), refers to domestic regulations found in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and applicable international regulations, such as the IMDG Code, authorized by § 171.12. In regard to the above-mentioned certification statement, you may want to petition for rulechange under § 106.31 of the HMR.
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.