Our first two sessions centered around Limited Quantities and Excepted Quantities. At this session, we’ll close the loop with, Consumer Commodity, ORM-D, Small Quantities Exceptions, Deminimis, and Materials of Trade Exceptions.

Before we get there however, please remember there is an American way (49CFR) and the rest of the world way (IMDG, ICAO, IATA, ADR, TDG, etc…). For appetizers, we’ll start with Consumer Commodity.

Consumer Commodity has dual citizenship. You’ll find it in 49CFR and ICAO and IATA. You will not find it in the IMDG. In 49CFR, they show it both ways – Domestic and International. Domestically, they call it Consumer Commodity and assign it to a Class called, ORM-D (Other Regulated Material – Domestic). This is a dying breed. The only requirement when transporting an ORM-D by Ground in the United States, is to Mark the package ORM-D, that’s it, nothing else. The catch, it’s a dying breed. The government has agreed to eliminate this Exception by the year 2020. They tried to eliminate it this year, but because of much fanfare, they extended it till 2020. That said, many carriers no longer accept it. It’s replacement? Limited Quantities by Ground – See session #1.

Now a Consumer Commodity for International Air, has an ID Number (baby UN Number) it is ID800 with a Proper Shipping Name of Consumer Commodity and it’s assigned to Class 9. IATA uses Packing Instruction 963 which lightens the load somewhat and does not require UN Specification Packaging. It is otherwise fully regulated and has to be Marked as a Limited Quantity – Session #1. You will not find Consumer Commodity in the IMDG (International Maritime Dangerous Goods) Regulations.

Next on the buffet, De Minimis. This is a relatively new entree and is available on all menus. Essentially, the portions are so tiny, they don’t even charge for them – they are not regulated so long as you maintain strict portion control.

This leaves us with Small Quantity Exceptions and Materials of Trade Exceptions. Both animals found only in the United States. Let’s start with Small Quantity Exception, 49CFR, Section 173.4. As with all of these Exceptions, not every Class or Division is authorized, there are strict limits on the quantities (30 grams or 30mL) per Inner Packagings, and strict requirements for the Packages themselves. The Small Quantity Exception is found only in America and available for Highway & Rail only.

For dessert, we have the Materials of Trade Exception. Again, this flavor is found only in America. 49CFR, Section 173.6. Available by Ground only in the United States. For me, the easiest way to understand the purpose of this Exception is look at all service industry vehicles driving around town and your neighborhood. The air conditioning company, landscapers, plumbers, welders, painters, to name a few. The purpose of the Exception is to support non-transportation companies during the operation of their businesses. As with the other Exceptions, there are limits to the Classes / Divisions authorized, Quantity Limits, and the Packagings. Otherwise, Materials of Trade don’t count calories, so long as they are transported in accordance with Section 173.6. It is not a giant loophole to which you can throw your shipments which are otherwise in transportation (being shipped).

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