Karmanterra, LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 June 11, 2026 Mr. Mark Samuels President Karmanterra LLC 2011 Palomar Airport Rd. Ste. 101 Carlsbad, CA 92011 Reference No. 25-0065 Dear Mr. Samuels: This letter is in response to your May 12, 2025, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of your charcoal-based product, currently classed as a Division 4.2 (Spontaneously Combustible) material. According to your letter, you have conducted United Nation (UN) Test N.4 (Test method for self-heating substances) through an independent International Organization for Standardization (ISO) / International Electrochemical Commission (IEC) 17025–accredited laboratory to evaluate the self‑heating properties of the material. You state that the test results demonstrate your product does not exhibit self-heating behavior as defined in § 173.124(b)(2). You ask whether your testing supports a determination that your pine-derived biocarbon does not meet the definition of a Division 4.2 hazardous material. As specified in § 173.22 of the HMR, it is the shipper's responsibility to properly class and describe a hazardous material. Such determinations are not required to be verified by this Office. Furthermore, the Pipeline and Hazardous Materials Safety Administration does not certify a shipper’s determination of whether a material is a hazardous material. However, based on the information and test results you included in your letter, it is the opinion of this Office that your pine-derived biocarbon would not be considered a Division 4.2 self‑heating material when transported within the United States. If your product does not meet any other hazard class as defined in 49 CFR Part 173, and is not a hazardous substance,#

Page 2hazardous waste, or marine pollutant, it is not subject to the HMR. Please note that international regulations may classify your material differently. 1 I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Alexander Wolcott Acting Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division 1 https://www.federalregister.gov/d/2026-02575/p-65#

Page 3Pollack, A. 25-0065 From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Cc: Hazmat Interps; Baker, Yul (PHMSA) Subject: FW: PHMSA Review Request – Non-Hazardous Determination (UN N.4) for Karmanterra Date: Monday, May 12, 2025 17:06:35 Attachments: Karmanterra-PHMSA-Classification-Review-Dossier-051225.pdf Hi Alice, Please see the below interpretation request with the attached supporting documentation. Let us know if you need anything else, -Breanna From: Mark Samuels <mark@karmanterra.com> Sent: Monday, May 12, 2025 2:10 PM To: Special Permits (PHMSA) <specialpermits@dot.gov> Cc: John Ryan <john@karmanterra.com>; PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov> Subject: PHMSA Review Request – Non-Hazardous Determination (UN N.4) for Karmanterra You don't often get email from mark@karmanterra.com. Learn why this is important CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Dear PHMSA Office of Hazardous Materials Safety, I am writing to formally request a classification review of our charcoal-based product, currently listed under UN1361, Division 4.2. We are submitting this request based on the results of a UN Test N.4 (Self-Heating Substances) conducted by an ISO/IEC 17025– accredited laboratory. The test indicates that our material does not exhibit self-heating properties and therefore does not meet the criteria for classification as a Division 4.2 hazardous material under 49 CFR § 173.124(b)(2). Please find attached a signed request letter outlining the submission, along with the following documentation: UN N.4 test report from Stonehouse Process Safety Inc. Material Safety Data Sheet (MSDS) and Technical Data Sheet (TDS) Product specifications, details, and certificate of analysis We kindly ask PHMSA to review the data and provide a written determination or letter of interpretation confirming whether the material can be considered non-hazardous under the#

Page 4HMR. This determination is essential for both domestic and international shipping compliance. Should you require any additional information or clarification, we would be happy to provide it promptly. Thank you for your time and consideration. Best regards, Mark image Mark Samuels President +1 (949) 439-0960 mark@karmanterra.com www.karmanterra.com twitter linkedin Karmanterra LLC 2011 Palomar Airport Rd. Ste. 101 Carlsbad, CA 92011#