DOT Hazmat Rules for Shipping Scrap Metal: 2026 Guide

Most clean ferrous and non-ferrous scrap is not regulated as hazardous material simply because it is scrap. However, loads containing batteries, hazardous liquids, lithium cells, contaminated equipment or other regulated components may fall under the U.S. Department of Transportation's Hazardous Materials Regulations.

What Are DOT Hazardous Materials Regulations?

The U.S. Department of Transportation regulates hazardous materials transportation primarily through the Hazardous Materials Regulations in 49 CFR Parts 171-180.

Those rules govern matters including classification, shipping descriptions, packaging, marking, labeling, placarding, emergency-response information, training and incident reporting.

Scrap metal itself is not automatically a hazardous material. The shipper must determine whether the actual material being offered for transportation meets a hazardous-material description or classification under the regulations.

Which Scrap Loads May Require Hazmat Compliance?

Wet Lead-Acid Batteries

Wet electric-storage batteries filled with acid are listed in the Hazardous Materials Table as:

• UN2794 — Batteries, wet, filled with acid, electric storage
• Hazard Class 8 — Corrosive

However, highway and rail shipments of wet batteries may qualify for specific exceptions under 49 CFR §173.159 when all applicable conditions are satisfied.

For example, the highway/rail exception in §173.159(e) requires batteries to be loaded and braced to prevent damage and short circuits and generally prohibits other hazardous materials from being transported in the same vehicle when that exception is used.

Non-Spillable Batteries

Qualifying non-spillable electric-storage batteries are listed as:

• UN2800 — Batteries, wet, non-spillable, electric storage
• Hazard Class 8

A battery is not considered non-spillable merely because it has been drained. To qualify for the non-spillable exceptions in 49 CFR §173.159a, the battery must meet specific construction and performance conditions.

When those conditions are met and the batteries are properly secured and marked, qualifying non-spillable batteries can be excepted from most other Hazardous Materials Regulations, subject to the conditions in the rule.

Lithium Batteries in E-Scrap

Electronic scrap requires closer examination because devices may contain lithium batteries.

Relevant classifications can include:

• UN3480 — Lithium ion batteries
• UN3481 — Lithium ion batteries contained in equipment or packed with equipment
• UN3090 — Lithium metal batteries
• UN3091 — Lithium metal batteries contained in equipment or packed with equipment

A printed circuit board does not automatically become UN3090 simply because it is electronic scrap. Classification depends on the actual battery or hazardous component present and how it is being transported.

Clean Ferrous and Non-Ferrous Scrap

Clean steel, copper, aluminum and similar scrap that contains no regulated hazardous material, free liquid or other hazardous component generally does not require a UN identification number solely because it is scrap metal.

Contamination can change that conclusion. Oils, chemicals, residues, batteries or other components must be evaluated separately.

ISRI/ReMA Scrap Specifications Are Not DOT Classifications

Commercial scrap specifications and DOT hazardous-materials classifications serve different purposes.

For example, the scrap specification traditionally identified as RAILS refers to lead battery plates. The specification itself does not determine which DOT proper shipping name or UN number applies.

The material must still be evaluated under the Hazardous Materials Regulations based on its actual condition and composition.

Do not automatically assign UN2794, UN2800 or any other transportation classification solely from a scrap commodity code.

How to Screen a Scrap Load Before Shipping

A pre-shipment inspection should look for conditions that may indicate additional regulatory review is needed, including:

• Wet or damaged lead-acid batteries
• Loose or damaged lithium batteries
• Free liquids or leaking containers
• Oil or chemical residues
• Electronic equipment with batteries still installed
• Capacitors, mercury-containing devices or other regulated components
• Damaged packages or exposed battery terminals

Visual inspection is only a screening tool. It does not replace proper hazardous-material classification.

Magnet Tests Do Not Determine Hazmat Status

A magnet can help separate ferrous from non-ferrous metal, but it provides no reliable information about whether a load is regulated as hazardous material.

A non-magnetic load may still contain batteries, chemicals or hazardous components, while a ferrous load may be contaminated with regulated material.

How to Prepare a Potential Hazmat Scrap Shipment

1. Identify the Material

Determine exactly what is being shipped, including batteries, liquids, electronics and any known contaminants.

2. Determine the Correct DOT Classification

Check the Hazardous Materials Table in 49 CFR §172.101 and the applicable material-specific provisions.

Do not select a UN number based only on the material's commercial scrap name.

3. Check for Applicable Exceptions

Some materials have important exceptions that can substantially change the shipping requirements.

Wet electric-storage batteries may qualify for the highway or rail provisions in §173.159, while qualifying non-spillable batteries may be excepted under §173.159a.

Conditions must be followed exactly. An exception should never be assumed simply because a shipment is going to a recycler.

4. Use the Packaging Authorized for the Material

Packaging requirements depend on the specific hazardous material and applicable exception.

There is no universal rule requiring all battery or contaminated-scrap shipments to be placed in UN-rated steel drums or IBCs.

For wet batteries, the regulations specifically address packaging, securement, prevention of short circuits and protection against leakage or damage.

5. Apply Required Markings, Labels and Placards

Marking, labeling and placarding requirements depend on the material, packaging configuration, quantity and any regulatory exception being used.

Wet acid batteries are Class 8 corrosive material when fully regulated, but that does not mean every truck carrying batteries automatically requires Class 8 placards.

Placarding must be determined under 49 CFR Part 172, Subpart F.

6. Prepare Shipping Papers When Required

For hazardous materials subject to shipping-paper requirements, the basic description normally includes:

• UN or NA identification number
• Proper shipping name
• Hazard class or division
• Packing group, when assigned
• Required quantity and package information

An emergency-response telephone number must also be provided when required by the regulations.

An Emergency Response Guidebook guide number is not required to appear on the shipping paper.

7. Confirm Employee Training

Employees whose jobs directly affect hazardous-materials transportation safety are considered hazmat employees and must receive required DOT training.

Training generally includes:

• General awareness and familiarization
• Function-specific training
• Safety training
• Security-awareness training
• In-depth security training when a security plan applies

Recurrent hazmat employee training is required at least once every three years.

8. Confirm Driver and Carrier Requirements

A commercial driver must hold a hazardous-materials endorsement when operating a commercial motor vehicle carrying hazardous material that meets the CDL hazmat definition, which generally includes material required to be placarded.

Federal rules require hazardous-materials endorsements to be renewed at least every five years, with a Transportation Security Administration security threat assessment.

Carrier operating status and safety information can be checked through the Federal Motor Carrier Safety Administration's SAFER Company Snapshot.

PHMSA registration should also be verified when the carrier or shipper handles materials and quantities that trigger federal hazmat-registration requirements.

Mixed Scrap Loads Require Careful Review

Hazardous and non-hazardous material can sometimes be transported in the same vehicle, but the applicable rules depend on the materials involved, compatibility, packaging and the exception being used.

A particularly important example involves the highway and rail battery exception under §173.159(e). If a shipper relies on that exception for wet electric-storage batteries, other hazardous materials generally may not be transported in the same vehicle.

Mixed scrap loads therefore should be reviewed before loading rather than assuming segregation alone makes the shipment compliant.

Load Securement and Safe Handling

Regardless of hazardous-material classification, scrap loads should be secured to prevent movement, damage and release during transportation.

For batteries, terminals and cases must be protected against damage and short circuits as required by the applicable rule.

Workers handling batteries or contaminated material should follow the employer's safety procedures, applicable Safety Data Sheets and required OSHA or DOT training.

Emergency-response actions should be based on the material involved and the company's approved response procedures. Do not automatically neutralize spills or apply chemicals unless the response method is appropriate for that material and performed by trained personnel.

Hazmat Incident Reporting

Not every transportation incident triggers the same reporting requirement.

Under 49 CFR §171.15, certain serious hazardous-material incidents require notice to the National Response Center as soon as practical but no later than 12 hours after the incident.

Under 49 CFR §171.16, specified incidents require a written Hazardous Materials Incident Report to PHMSA within 30 days.

Companies should review the actual reporting criteria rather than assuming that every spill or injury follows the same timeline.

Transportation Costs and Hazmat Surcharges

DOT does not establish a standard transportation surcharge for scrap metal or hazardous-material loads.

Actual freight costs depend on factors including:

• Distance
• Shipment weight
• Material classification
• Packaging and handling requirements
• Carrier insurance and compliance costs
• Equipment type
• Fuel and market conditions
• Truck, rail or intermodal service

Shippers should obtain current carrier quotes rather than relying on a fixed per-ton hazmat surcharge.

How to Verify a Transporter

The ScrapMonster Company Directory can be used to identify logistics, recycling and transportation businesses.

However, directory listings should not be treated as proof of DOT or hazmat authority.

Before tendering regulated hazardous material, verify the carrier independently using:

• FMCSA SAFER Company Snapshot for USDOT status, operating information and available safety data
• PHMSA Hazardous Materials Registration when registration requirements apply
• The carrier's current insurance, operating authority and applicable hazardous-material credentials

Official DOT Resources

• Pipeline and Hazardous Materials Safety Administration
• 49 CFR Hazardous Materials Regulations
• PHMSA Hazmat Training Requirements
• FMCSA Carrier Safety Lookup

Frequently Asked Questions

Do all scrap battery shipments require hazmat shipping papers?

No. The answer depends on the battery type, its condition, transportation mode and whether a regulatory exception applies.

Wet lead-acid batteries may qualify for an exception under §173.159, while qualifying non-spillable batteries may qualify for the broader provisions in §173.159a.

Does a non-spillable battery automatically qualify as UN2800?

No. It must meet the regulatory criteria for a non-spillable battery. Simply draining a battery does not establish eligibility for the UN2800 exception.

Do wet battery loads always require Class 8 placards?

No. Class 8 is the relevant hazard class for fully regulated wet acid batteries, but placarding depends on quantity, package type, mode and any applicable exception.

How often must hazmat employees receive recurrent training?

At least once every three years under 49 CFR §172.704.

How often is a CDL hazardous-materials endorsement renewed?

Federal rules require states to renew hazardous-materials endorsements every five years or less, including the required TSA security threat assessment.

Can hazardous and non-hazardous scrap be shipped together?

Sometimes, but the applicable segregation, packaging and exception requirements must be reviewed first. For example, the §173.159(e) wet-battery exception generally prohibits other hazardous materials in the same vehicle.

Is a printed circuit board automatically UN3090?

No. UN3090 applies to lithium metal batteries. Electronic scrap must be classified according to the batteries or hazardous components actually present and how they are packaged for transportation.

Bottom Line

Scrap-metal transportation compliance begins with correct classification. Clean metal and a battery load cannot be treated the same way simply because both are destined for recycling.

Identify the material, determine whether it is regulated, review any available exceptions, use the correct packaging and documentation, and verify that employees and carriers meet applicable requirements before the shipment moves.

When classification is uncertain, consult PHMSA or a qualified hazardous-materials professional before shipping.