MSC Mediterranean Shipping Company (USA) Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 January 22, 2026 Mr. Scott Higman MSC Mediterranean Shipping Company (USA) Inc. 700 Watermark Blvd. Mt. Pleasant, SC 29464 Reference No. 26-0008 Dear Mr. Higman: This is in response to your January 15, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of unpackaged vehicles in cargo transport units (CTUs) under the International Maritime Dangerous Goods (IMDG) Code. Specifically, you ask whether unpackaged vehicles shipped inside of CTUs require placarding when offered for transport in accordance with special provision 962 of Amendment 42-24 of the IMDG Code. The answer to your question is no. Special provision 962 of the IMDG Code addresses when marking, labeling, and placarding requirements apply to packaged vehicles, and excludes unpackaged vehicles from these requirements. As you note in your email, the next amendment to the IMDG Code—i.e., Amendment 43-26, applicable on January 1, 2028—once adopted will require placarding for all vehicles in CTUs whether packaged or unpackaged. Amendments 42- 24 and 43-26 to the IMDG Code may be considered by PHMSA for incorporation by reference in a future harmonization rulemaking. We note that permissive placarding is authorized by both the currently effective HMR and the currently effective IMDG Code. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Matthew Nickels Acting Director, Standards & Rulemaking Division Office of Hazardous Materials Safety#

Page 2Pollack, A. 26-0008 From: INFOCNTR (PHMSA) To: Baker, Yul (PHMSA) Cc: Hazmat Interps Subject: FW: Clarification on IMDG Code Placarding for UN 3556 Lithium-Ion Battery Powered Vehicles Date: Thursday, January 15, 2026 14:06:55 Attachments: image001.png image002.png image003.png Good afternoon, Please see the following interpretation request. Let us know if you need anything else. Best, Aminah From: scott.higman@msc.com <scott.higman@msc.com> Sent: Thursday, January 15, 2026 9:48 AM To: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov>; HQS-SMB-CG-ENG-5-HazardousMaterialDivision@uscg.mil Cc: Michael.P.Comerford@uscg.mil; hillary.sadoff@uscg.mil; PhillipVictor.T.Romero@uscg.mil; stefan.gielen@msc.com; leslie.godelaine@msc.com; yve.vanlimbergen@msc.com; christopher.parvin@msc.com; neill.bishop@msc.com; kelley.glover@msc.com Subject: Clarification on IMDG Code Placarding for UN 3556 Lithium-Ion Battery Powered Vehicles You don't often get email from scott.higman@msc.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. To whom it may concern, I write today with a sense of urgency to obtain a formal DOT interpretation for the transportation of the subject commodities. We are currently experiencing significant challenges as several U.S. terminals and port authorities are interpreting IMDG Code placarding requirements and Special Provisions for UN 3556 Lithium-Ion Battery Powered Vehicles differently based on comments from fire departments and federal field-level authorities. This inconsistency has created confusion and resulted in an economic impact, as U.S. export cargo on terminal is presently at an impasse. As of the date of this request, over 100 TEUs of U.S. Exports are being delayed at U.S. ports due the confusion and we believe a rapid formal determination is needed to alleviate the problem and answer the question: “To placard or not placard the outside of CTUs said to contain Lithium-Ion Battery Powered Vehicles UN 3556 Class 9 commodities that are not placed inside the CTU (Dry Van Container) and not enclosed in crates or overpacks inside the container. As you may be aware, this placarding issue was addressed during IMO Editorial & Technical Group (E&T Group) #43, where it was collectively recognized that the confusion will be resolved with Amendment 43-26, which will require external placarding on Cargo Transport Units (CTUs). Until that amendment takes effect, MSC maintains the interpretation that a shipping container (CTU) is not considered packaging—it is a transport unit and therefore, Class 9 placards should not be affixed to a container carrying UN 3556 un-crated vehicles (un-packaged) as cargo, in accordance with Special Provision (SP) 962. I am seeking clarification on the DOT, PHMSA and U.S. Coast Guard’s interpretation of this matter to ensure compliance and operational continuity. Thank you for your attention to this issue. Please feel free to contact me by or email to discuss further. Excerpt from NCB HAZCHECK for UN 3556#

Page 3IMDG DG List and applicable Special Provisions Sincerely and Best Regards, Scott Higman Director, Safety, Security, and Compliance MSC MEDITERRANEAN SHIPPING COMPANY (USA) INC. 700 Watermark Blvd., Mt. Pleasant, SC 29464 USA T: +1 (843) 212-1797 M: +1 (843) 329 2286 W: www.msc.com (24/7) phone: +1 (332) 233-8351 As agent for MSC Mediterranean Shipping Company S.A., Geneva To find more about the processing of your personal data please click here https://www.msc.com/-/media/files/legal-files/general-data-protection-notice-for-customer2024.pdf . This message and any associated files (together the “Contents”) are intended solely for the addressee(s). The Contents are confidential and may contain private information or information that is subject to copyright or is a trade secret or which is privileged. Views or opinions expressed herein do not necessarily represent views or opinions of MSC Mediterranean Shipping Company, its agents or their affiliated companies and may only be the view or opinion of the author. If you are not the intended recipient of this email, you must not use, print, copy, store, forward, or disclose it or act in reliance of the Contents. Please destroy all copies of the message and any associated files and notify the sender immediately that you have received it in error. Thank you for your cooperation.------MSC LEGAL DISCLAIMER Sensitivity: Internal#