Butane Lighters
Pipeline and Hazardous Materials Safety Administration · May 12, 1999 · Reference No. 99-0122
Interprets: 49 CFR § 172.504
Reggie’s quick take
A company that ships butane lighters asked whether a truck carrying less than 1,001 pounds of them must display placards. The agency said no. Butane is a Division 2.1 flammable gas, and placards are required only when the total gross weight of packages on a vehicle goes over 1,001 pounds. Under the agency's reading, a load under that amount does not need placards. The letter also notes that § 173.308(b) exempts shipments of up to 1,500 lighters in one motor vehicle from certain placarding and marking rules in Part 172.
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 a letter from Mr. Joe Fetchel of New York Lighter Co., regarding the placarding requirements of the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). Specifically the question is whether a transport vehicle containing less than 1001 pounds of lighters containing butane is required to be placarded.
Butane is a Division 2.1 flammable gas which requires placarding only when the aggregate gross weight per vehicle exceeds 1001 pounds. Aggregate gross weight means a packaging plus its contents. In your scenario with less than 1001 pounds of lighters on a transport vehicle, no placarding is required. For your information, § 173.308(b) provides an exception from subparts C through H of Part 172 when no more than 1500 lighters are transported in one motor vehicle.
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.