Zhen Hua Trading Limited — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation SEP 2 0 2001 peeiat Programs Administration Mr. Charles Ho Ref. No. 01-0051 Senior Manager Zhen Hua Trading Limited Room 2003, 20/F, C. C. Wu Building Wanchai, Hong Kong 302-308 Hennessy Road Dear Mr. Ho: This responds to your letter regarding the classification of "wood charcoal" as a dangerous good under the U.S. Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and your plans to export this product to the U.S. whether a material meets the definition of a hazard class or is Under the HMR, it is the shipper's responsibility to determine not subject to the regulations. normally performed by this office. We will, however, provide assistance when possible, in the classification of a material. Your letter did not describe the composition or physical form of the wood charcoal. Wood charcoal may meet the definition of a testing in accordance with the UN Manual Tests and Criteria Division 4.2, spontaneously combustible material, if, after (extract enclosed) it is determined the charcoal meets the hazard definition of class criteria. Division However, if the material does not meet the 4.2 or any other hazard class or division in the HMR, the material would not be subject to the HMR. you contact the United States Department of Commerce's Trade For information regarding trade with the U.S., we suggest that information Center at tic@ita.doc.qov or the International Trade Administration at 1-800-USA-TRADE. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. ".. Transportation Regulations Specialist Office of Hazardous Materials Standards Enclosure 1112 010051#

Page 2Stevens $171.12 Zhen Hua Trading Limited Export Tel: (852) 2527 1125 http://www.zhenhua.com.hk E-mail: enquiry@zhenhua.com.hk Applicability 01-0051 Ref:zhbvilother\inquirylusdot01 29 January 2001 U.S.Department of Transportation Tel: 202 3664488 Office of Hazardous Materials 4007% Street SW Washington, DC 20590-0001 U.S.A. Attn: Director Dear Sir/ Madam, Inquiry of the Importation of Wood Charcoal We are a company dealing with charcoal business in Hong Kong, and we plan to export charcoal products to US. We would like to know the following inquiries: 1. Whether there are any restrictions imposed by the US when wood charcoals are imported • into US. Any quota, license, or other documents are required before we export. 2. Whether our wood charcoals would be classified as dangerous goods during transport, loading and unloading. If they are really classified as dangerous goods, what suggestions you could provide us to solve that problem. Thank you for your kind attention and look forward to receiving your soon reply. Kind regards Charles Ho Senior Manager CH/MF#