FAQ: What is a Special Permit?

By August 3, 2017 April 19th, 2021 49 CFR

Special Permit, FAQ: What is a Special Permit?, ICC Compliance Center Inc - USA

If you ever navigate our packaging section on our website, you will notice a section for U.S. Special Permit Kits.

You may ask yourself, what is a special permit and how does it apply to packaging? Well, basically special permits allow a shipper to perform a function that is not currently authorized by the regulations, or not perform a function currently required under the PHMSA regulations. Below are answers to questions regarding special permits.

Q. Why would someone need a special permit?

A. Special permits can provide relief from specific regulations when shipping dangerous goods. For example, it can allow a shipper to transport their dangerous goods in a specific UN-rated package without having to use hazard labels, as long as they adhere to the required provisions stated within the Special Permit.

Q. How do you apply for a special permit?

A. An application has to be completed and submitted to the US DOT along with specific documentation including written descriptions, drawings, flow charts, plans and other supporting documents.

Q. Do special permits expire?

A. Yes. Special permits expire after a period of time and the manufacturer must re-apply with the Department of Transportation.

Q. Does the Department of Transportation reject applications for a special permit?

A. The application must demonstrate that the special permit achieves a level of safety at least equal to that required by regulation, or if a required safety level does not exist, is consistent with the public interest.

Q. How long does it take for the DOT to process your special permit application?

A. Generally speaking, the DOT will attempt to process the application within 120 days. However this process can take months longer depending on the circumstances.

Q. What are some helpful tips when applying for a special permit?


  1. Read the regulatory requirements very carefully. Familiarize yourself with the applicable provisions of the US DOT’s Hazardous Materials Regulations (HMR) and the international standards that may apply.
  2. Carefully review the US DOT PHMSA website for letters of interpretation that may exist. You may find that a DOT special permit is not required because there might have been a previous ruling issued on the subject.
  3. Read the requirements for completing and submitting an application for permit and/or approval very carefully. If any piece of information is missing, chances are you will be denied and have to start the process all over again.

For more information on special permits reference 49 CFR 190.341, or visit PHMSA’s website.

An as always if you wish to purchase special permit packaging from ICC Compliance Center visit our website.

Michael Zendano

Michael Zendano

Michael Zendano started with ICC Compliance Center back in 2016 with several years in the packaging field as a Quality Control Manager. In addition, he has 8 years experience in teaching. Michael works at the Niagara Falls Office as the Regulatory Packaging Expert where he manages packaging projects and procedures and is a member of the Institute of Packaging Professionals (IOPP) and The Chemical Packaging Committee (CPC) . Degrees: M.S. Science of Education.