Rounding Maximum Gross Weight in Certification Marking
Pipeline and Hazardous Materials Safety Administration · Feb 7, 1995 · Reference No. 95-0348
Interprets: 49 CFR § 178.503
Reggie’s quick take
Someone asked whether the maximum gross weight in the certification marking on a fiberboard combination packaging should be rounded up or down. PHMSA said that if the maximum gross mass marking under § 178.503(4)(ii) is to be a whole number, it must be rounded down. A packaging cannot be filled above its marked maximum gross mass. The letter's example: a packaging weighing between 20.1 and 20.9 kg should be tested at 21 kg and marked 21 kg.
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 of November 10, 1994 asking whether the maximum gross weight in the certification marking on a fiberboard combination packaging should be rounded up or down.
It is the opinion of this office that if the maximum gross mass marking specified in 49 CFR 178.503(4)(ii) is to appear as a whole number, it must be rounded down. It should be noted that a packaging cannot be filled to a gross mass greater than the maximum gross mass marked on the packaging. For example, if a packaging would weigh between 20.1 and 20.9 kg it should be tested at 21 kg and marked 21 kg.
If we can be of further assistance, please feel free to contact us.
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.