Updated Guide: When can you use Materials of Trade?

Materials of Trade (MOT) are specific hazardous materials transported in small quantities for business-related purposes such as servicing, maintenance, or sales. The DOT allows limited exceptions for these to reduce regulatory burden.

What’s Allowed Under the MOT Exception?

You may transport hazardous materials under the MOT exception if:

• They are used in direct support of a business (e.g., repair, agriculture, service industry)
• The material type and quantity meet the specified limits

Permitted Hazard Classes

Under 49 CFR §173.6, the following hazard classes are permitted:

• Class 3 – Flammable liquids
• Class 4.1 – Flammable solids
• Class 5.1 & 5.2 – Oxidizers and organic peroxides
• Class 6.1 – Toxic substances
• Class 8 – Corrosives
• Class 9 – Miscellaneous (see bulk exception)
• Division 2.1 & 2.2 gases in limited packages

Quantity Limits

🆕 Class 9 Bulk Diluted Mixtures

DOT now allows transportation of Class 9 diluted mixtures (≤2% hazard) in bulk under MOT rules:

• Up to 1,500 liters (400 gallons)
• Must be in a properly secured bulk package
• Requires UN ID markings on two sides
• Must show a Class 9 placard or white square-on-point (min. 273 mm)

🏷️ Marking & Labeling

• All packages must be securely closed and leakproof
• Mark with the common or proper shipping name
• DOT-spec cylinders (non-DOT-39) must have standard labels
• DOT-39 cylinders must be marked per §178.65(i)

Operator Notification

• Operator must be informed of MOT transport
• Must know if any package contains a reportable quantity (RQ)
• General awareness training is required (no formal HAZMAT training)

💡 Benefits of the MOT Exception

Using the MOT exception can eliminate the need for:

• Shipping papers
• Formal HAZMAT certification
• Placards (except Class 9 bulk)
• UN-specification packaging (some exceptions apply)