PHMSA letter of interpretation

Loading Perfumery Products Aboard Passenger Aircraft

Pipeline and Hazardous Materials Safety Administration · Jul 22, 1999 · Reference No. 99-0101

PHMSA says to use caution with this letter. On May 2, 2007, PHMSA finalized Docket HM-215F, which consolidated the conditions and limitations for use of international standards in Part 171 Subpart C. As a result, the references provided in this guidance are no longer accurate. Please see Part 171, Subpart C for the current requirements for conditions and limitations for the use of international standards. Although not all references to requirements previously codified in § 171.11 have parallel requirements in Part 171, Subpart C, you may wish to review § 171.22 for additional information.

Interprets: 49 CFR § 171.11, 49 CFR § 171.22

Reggie’s quick take

Someone asked whether U.S. variations or government restrictions apply to loading perfumery products (Class 3, UN1266, PG II or III) onto passenger aircraft. The agency's answer covers products imported into the U.S. that are not limited quantities or consumer commodities and are packed under ICAO rules. These must meet 49 CFR 171.11 and certain U.S. variations. Variation 1 requires English on package markings and the transport document. Variation 12 requires a 24-hour emergency phone number. Variation 4 applies if hazardous substances are identified. Any applicable variation must be listed on the Shipper's Declaration.

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 4, 1999, regarding the applicability of the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods-by Air (ICAO). Specifically, you asked whether any United States (U.S.) Variations or U.S. Government restrictions apply to the loading of Perfumery products, 3, UN1266, PG II or PG III onto a passenger aircraft.

A Perfumery product being imported :into the U.S. that is not a limited quantity or a consumer commodity, and is properly packaged for transportation in accordance with ICAO must conform, to the requirements in 49 CFR 171.11 (copy enclosed) and certain U.S. variations. The variations that may apply to your products are the following: U.S. Variation 1 requiring the use of English for all required package markings and for the dangerous goods transport document, U.S. Variation 12 requiring the shipper to provide a 24-hour emergency response telephone number and, if applicable, U.S. Variation 4 requiring the identification of hazardous substances. The applicable variation must be listed on the Shipper's Declaration of Dangerous Goods.

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.