A limited quantity shipment may contain less hazardous material than a fully regulated shipment, but the compliance details surrounding that package still matter. Now, PHMSA has finalized a change that gives certain shippers more flexibility: HM-268B allows a reduced-size limited quantity marking for qualifying shipments moving by highway, rail, or vessel. The rule is effective September 3, 2026.
For shippers, this is more than a smaller diamond-shaped mark. It changes how limited quantity communication can be incorporated into package labeling, particularly where label real estate is tight. But the flexibility has boundaries. It does not extend to air shipments, and the new reduced-size marking cannot simply be transferred to the outside of an overpack. Understanding those distinctions before changing labels is critical.
Hazmat University helps hazmat employees build that understanding through online hazmat training courses covering limited quantities and the requirements applicable to different transportation modes. Rather than treating the new rule as an isolated labeling change, training can help employees understand where the new flexibility fits within the larger regulatory framework.
What HM-268B Changes
HM-268B addresses a specific problem: the amount of physical space required for the limited quantity marking on packages. PHMSA’s final rule revises 49 CFR 172.315(a)(2) to permit a reduced-size limited quantity marking on the package shipping label for certain shipments transported by modes other than aircraft. The final rule also revises 49 CFR 173.25(a)(6) to make clear that the reduced-size marking is not authorized on an overpack.
The change originated with COSTHA Petition P-1778, which sought to incorporate the relief previously available under DOT Special Permit 21015 into the Hazardous Materials Regulations. PHMSA identified the change as a way to remove unnecessary regulatory burdens for domestic limited quantity shippers and carriers.
The new rule is not an invitation to redesign every limited quantity label without regard to the underlying requirements. It’s a targeted regulatory accommodation. The package must still qualify for the limited quantity provisions, and the marking must still satisfy the applicable requirements for durability, legibility, visibility, and proper placement.
For companies shipping thousands of similarly configured packages, however, the practical effect can be significant. A smaller marking can provide additional room on constrained package surfaces and may make it easier to consolidate required communication on a shipping label.
What the Smaller Limited Quantity Mark Means in Practice
The biggest operational mistake would be to interpret “smaller” as “less important.” The limited quantity marking continues to communicate that the package is being transported under the applicable limited quantity provisions. The regulatory flexibility concerns its size, not the importance of the communication.
Shippers reviewing their packaging and labeling procedures should focus on:
- Package configuration: Determine which package designs create genuine space constraints and whether the reduced-size option is appropriate for those configurations.
- Transportation mode: Confirm that the shipment is moving by a mode for which the new reduced-size marking is authorized.
- Label design: Review whether the LQ mark can be incorporated into an existing shipping label without compromising readability or other required information.
- Procedures: Update written work instructions, label templates, and quality-control checks rather than allowing employees to make ad hoc changes.
- Training: Make sure hazmat employees understand the difference between the standard LQ marking requirements and the newly authorized reduced-size option.
Regulatory changes can create a dangerous gap between what a company has changed operationally and what its employees actually understand. A revised label template does not automatically mean the people preparing shipments understand when that template may be used. That is where training becomes part of implementation, rather than an afterthought.
The Rule Does Not Apply to Air Shipments
One of the most important limitations in HM-268B is the transportation-mode distinction. The final rule authorizes the reduced-size marking for limited quantity shipments by highway, rail, or vessel. It doesn’t extend that same reduced-size option to shipments transported by aircraft.
This creates an immediate compliance consideration for companies operating across multiple transportation modes. A packaging or labeling procedure that works for a ground shipment cannot automatically be carried over to an air shipment simply because the material qualifies as a limited quantity under another regulatory framework.
Air transportation brings its own dangerous goods requirements, including the applicable provisions governing the preparation and marking of packages. Employees responsible for multimodal shipments therefore need to recognize that “limited quantity” isn’t a universal instruction to apply the same label treatment regardless of the transportation mode.
A company shipping the same product by ground and air may need different operational checks depending on the shipment’s transportation path. That distinction should be reflected in employee training, internal procedures, and shipment review.
Do Not Put the Reduced-Size Mark on an Overpack
The second major limitation is equally important: HM-268B does not authorize the reduced-size limited quantity marking on the outside of an overpack. PHMSA specifically revised 49 CFR 173.25(a)(6) to address this issue.
This means shippers need to distinguish between the marking applied to an individual limited quantity package and the marking requirements that apply when those packages are placed into an overpack.
That distinction can become complicated in real distribution environments. Packages may be consolidated onto pallets, placed into shrink wrap, or otherwise grouped for handling and transportation. Once an overpack is created, employees need to evaluate the visibility and marking requirements applicable to the overpack instead of assuming the marking on the individual packages resolves every requirement.
The new rule therefore creates flexibility at the package level without eliminating the separate compliance considerations associated with overpacks.
Three Things LQ Shippers Should Do Before September 3, 2026
The effective date gives companies an opportunity to prepare rather than react. Since HM-268B takes effect September 3, 2026, organizations should use the period before implementation to determine whether the new option actually benefits their operations.
- Audit current labels: Identify package designs where the existing LQ marking consumes valuable label space or creates layout problems.
- Separate transportation modes: Review ground, vessel, and air workflows independently so employees do not apply the new ground-and-vessel flexibility to air shipments.
- Review overpack procedures: Make sure the reduced-size mark isn’t incorporated into an overpack labeling procedure where it’s not authorized.
- Update training materials: Revise internal instructions and employee training to reflect the new regulatory option and its limitations.
- Test before deployment: Validate revised labels and procedures before rolling them into routine production.
A measured implementation process is preferable to simply shrinking an existing graphic and assuming the regulatory problem has been solved.
Why LQ Training Matters More When Rules Change
HM-268B illustrates why hazmat training can’t be reduced to memorizing individual markings. Employees need to understand how a regulatory provision interacts with packaging, transportation modes, labeling, and operational procedures.
For a company implementing HM-268B, that broader understanding matters. An employee who knows that a limited quantity mark can be smaller may still make the wrong decision if that employee does not recognize that the flexibility is tied to the transportation mode or does not understand the separate treatment of overpacks.
Hazmat University provides online hazmat training courses designed around the regulatory requirements applicable to dangerous goods transportation. Its courses include training focused specifically on dangerous goods in limited quantities, as well as ground, air, vessel, and multimodal training. The courses incorporate current regulatory information and use interactive lessons and quizzes to reinforce the material.
Online hazmat training also gives organizations a way to bring employees up to speed as regulatory requirements evolve. Hazmat University courses are self-paced and flexible, allowing hazmat employees to complete training without waiting for a scheduled classroom session.
A Smaller Mark Does Not Mean Smaller Compliance Responsibilities
HM-268B is a deregulatory change, but it does not eliminate the need for careful shipment preparation. PHMSA’s final rule is designed to remove an unnecessary burden while preserving the communication function of the limited quantity marking. The change allows greater flexibility for qualifying highway, rail, and vessel shipments, but it draws clear boundaries around air transportation and overpacks.
For LQ shippers, the smart response is not simply to change the artwork. It is to examine where the new option fits, update procedures, and make sure the employees responsible for preparing shipments understand the difference between what the rule permits and what it does not.
Choose the Latest Online Hazmat Courses and Prepare Your Team for the New LQ Requirements
Regulatory changes become easier to manage when the people applying them understand the reasoning behind the requirements. Hazmat University’s online Limited Quantities training can help hazmat employees build that foundation while keeping their training accessible, structured, and aligned with current dangerous goods transportation requirements.
Whether your operation ships limited quantities exclusively by ground or moves hazardous materials through multiple transportation modes, training should reflect the actual responsibilities your employees perform. Hazmat University offers up-to-date online hazmat courses for initial and recurrent training, along with mode-specific and multimodal options.
Before HM-268B takes effect, give your team more than a revised label template. Give them the regulatory understanding to use the new flexibility correctly. Contact us today to discuss the training courses that fit your organization best.
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