Certification Marks
Pipeline and Hazardous Materials Safety Administration · May 30, 1995 · Reference No. 95-0342
Interprets: 49 CFR § 178.503
This is in response to your letter concerning date of manufacture in the UN certification of a 4G combination packaging. I apologize for the delay in responding and regret any inconvenience it may have caused.
As required by § 178.503, the "year of manufacture" indicated in the certification mark means the year when the package was manufactured or assembled. Depending on the contract you may have with a 4G (or other) supplier, year of manufacture could be the year in which the 4G fiberboard box is manufactured and provided for assembly, or the year the entire package is assembled prior to filling.
In the arrangement you describe, pre-printed paper bearing the certification mark may be used to complete the certified 4G combination packaging.
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.