Lynch Imports, LLC — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue, SE Washington, DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration June 8, 2026 Ms. Elizabeth Lynch Lynch Imports, LLC 11628 State Road 46 Sunman, IN 47041 Reference No. 26-0058 Dear Ms. Lynch: This letter is in response to your May 8, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of fireworks. Specifically, you seek clarification on behalf of your retail customers who purchase Division 1.3G and 1.4G fireworks. You state that your customers purchase fireworks for personal use, receive no compensation for their shows, and do not operate in commerce. You note that these customers occasionally encounter local officials who believe that HMR requirements, such as placarding, apply to your customers’ personal vehicles. You ask if the above scenario is subject to the HMR. No. As provided by § 171.1(d)(6), the transportation of a hazardous material, including Division 1.3G and 1.4G display fireworks, by an individual for non-commercial purposes in a private motor vehicle, including a leased or rented motor vehicle, is not subject to the requirements of the HMR, such as placarding. Please note that any trade or transportation within the United States, including non-profit operations, is considered commercial. See PHMSA Office of the Chief Counsel Letter of Interpretation1. In addition, note that even though not subject to the HMR, the purchase, movement, possession, and storage of fireworks by persons not operating in commerce may still be subject to other federal, state, or local restrictions. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Arthur Pollack Acting Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division 1 Paragon Astronautics, Letter of Interpretation CHI-00-002, available at: https://www.phmsa.dot.gov/regulations/title49/interp/chi-00-002#

Page 226-0058 Pollack ---------- Forwarded message --------- From: Lynch Imports <sales@lynchimportsllc.com> Date: Fri, May 8, 2026 at 1:58ÔÇ»PM Subject: Letter of Interpretation Request To: <infocntr@dot.gov> Hi. My name is Elizabeth Lynch and I am a co-owner of Lynch Imports, LLC. We are a wholesaler of 1.3g professional and 1.4g consumer and professional products, and we have a number of customers who purchase and shoot fireworks for their own personal enjoyment. They are not in commerce and receive no compensation for their shows. It is not uncommon for them to encounter various officials who are confused about whether or not the CFR regulations apply to these customers. For example, one of our customers spoke to an Ohio fire marshall recently who insisted that he had to placard his fireworks even though he was not in commerce.┬á We recently had a PHMSA inspection and discussed these issues with the inspector, who recommended that we email you and make a formal request for a letter of interpretation of the question: "If I am not in commerce and I am picking up fireworks for personal use, am I subject to 49 CFR?" We would like to provide this letter to our customers if/when they run into issues or confusion.┬á Our mailing address is: Lynch Imports, LLC 11628 State Road 46 Sunman, IN 47041 Our office phone number is: (812)623-0099 Thank you. Elizabeth#