Shipping Name Determination
Pipeline and Hazardous Materials Safety Administration · Jun 1, 1999 · Reference No. 98-0239
Interprets: 49 CFR § 172.101
Reggie’s quick take
A company that ships a coating product asked which proper shipping name to use: "Coating solution" or "Paint UN1263." PHMSA said the material may properly be described as either "paint" or "coating solution." Both names cover a wide range of products, so PHMSA left the choice to the manufacturer or the shipper who packages the product.
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 requesting clarification on how to determine a proper shipping name in accordance with the hazardous materials regulations. You state that you have a different opinion than the manufacturer of your product concerning the marking of cartons and proper shipping name assignment. Specifically, you state that the manufacturer of your product prefers your company use the proper shipping name "Coating solution" whereas your company prefers using the name "Paint UN1263." You asked which name is most appropriate under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Based on the information you provided, it is our determination that this material may be properly described by the generic proper shipping name "paint" or "coating solution." Both of these shipping descriptions include a wide range of products and we defer to the manufacturer's or subsequent shipper's judgement in the selection of the most appropriate proper shipping name.
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.