Is A Robot a Vehicle or Equipment?

When you ship a robot, it’s a vehicle, UN3556.

What do you think? DOT Special Provision 134(a) says this:

“a. For the purpose of this special provision, vehicles are self-propelled apparatus designed to carry one or more persons or goods.”

PHMSA agreed—at least two years ago when I requested this interpretation. https://lnkd.in/gK7tWThq

I know some will say, “what’s the big deal…” Well, for one thing as a “vehicle,” the state of charge of 25/30% will be mandatory as of 2026 for at least ICAO/IMDG. If it’s shipped as “equipment” under UN3481 in 2026, it can be shipped as fully charged (though it “should” be reduced as per PI967.)