Packaging selection
The shipper must determine that the packaging is authorized and compatible with the material and intended conditions of use.
HAZMAT compliance center
If it carries HAZMAT, details matter.
Packaging condition, design type, inspection, testing, marking, maintenance, repair and recordkeeping can all affect whether an IBC is appropriate for a regulated shipment.
Markings, records and responsibility
A visible mark is only one part of the compliance picture.
Packaging design, condition, testing, inspection, maintenance, marking, documentation and the intended material can each affect the questions a shipper must resolve.
- Confirm which requirements apply
- Distinguish a marking from its supporting record
- Evaluate the actual packaging and intended use
Separate the questions
A mark is not the whole record.
Periodic requirements
Composite IBCs can be subject to periodic inspection and leakproofness testing requirements based on type and use.
Records and markings
Visible markings and retained records serve related but different functions. Buyers should understand what each actually establishes.
PCC Rule
PCC requirements need a separate container review.
Covered pesticide IBCs can require specific opening controls, durable identification, DOT capability, registrant documentation and refilling controls. The IBC alone does not establish compliance.
Penalties & responsibility
Compliance failures are costly.
As verified August 26, 2026, the current eCFR lists a maximum civil penalty of $102,348 per violation and $238,809 when a violation results in specified serious consequences. Each day of a continuing violation can constitute a separate offense.
Amounts are time-sensitive. Verify the current 49 CFR 107.329 text before relying on a dollar figure. This center provides general education—not legal advice, regulatory advice or a packaging-authorization determination.
Beyond penalties
Packaging failures can affect people, property and the environment.
Improper filling, storage, closure, handling or transportation can increase the chance of a hazardous-material release—or make an incident harder to control.
People and responders
A release can expose employees, carriers, emergency responders and the public to harmful materials, fire or reactive hazards.
Air, soil and water
Escaped material can contaminate the surrounding environment and require containment, reporting, cleanup and disposal.
Property and operations
Incidents can damage vehicles, facilities, freight and other property while interrupting production, storage or transportation.
Scope depends on the activity. DOT hazardous-material requirements can apply to transportation functions, including certain loading, unloading, handling and storage incidental to movement. Workplace, environmental, fire-code and state or local requirements may also apply.
Buyer checklist
Questions to resolve before shipment.
Material
What is the proper shipping name, hazard class and packing group?
Packaging
Is the design type authorized for the material and quantity?
Condition
Is the IBC free from damage that could make it unsafe?
Qualification
Are applicable inspection and testing requirements current?
Documentation
What records must be retained or obtained?
Pesticides
Is this refillable packaging for sale or distribution, and has the registrant identified the IBC as an acceptable container for the specific product?
Primary regulatory sources
Verify against the current rule.
PHMSA enforcement mission and hazardous-material safety
Open PHMSA →
PHMSA hazardous-material incident statistics
Open PHMSA data →
49 CFR 180.352 — IBC retest, inspection and records
Open current eCFR →
49 CFR 178.813 — IBC leakproofness test
Open current eCFR →
49 CFR 107.329 — maximum civil penalties
Open current eCFR →
Appendix A to 49 CFR Part 107, Subpart D — civil-penalty guidelines
Open current eCFR →
Source links reviewed September 2, 2026. The eCFR and agency guidance are updated over time, so users should confirm the provisions applicable to their activity, material, location and date.
Start with the shipment