Guide
Reading the plate: 31HA1, dates and retest
The plate on a caged tote carries its UN design code, packing-group letter, manufacture date and the dates of its last tests. 31HA1 means a composite IBC with a plastic inner bottle and a steel outer cage.
What 31HA1 means
Under 49 CFR 178.702, the code 31HA1 names a composite IBC with a plastic inner receptacle and a steel outer packaging. Read it in pieces. The 3 marks an IBC for liquids. H marks the plastic inner receptacle and A the steel outer packaging. The closing 1 marks a rigid inner receptacle.
Almost every 275 or 330 gallon caged poly tote has this code. It is a design family, not a promise about what a particular tote held or whether it can be reused.
What else is on the plate
Under 49 CFR 178.703, the marking includes the UN symbol, the design code, the letter X, Y or Z for packing group, the month and year of manufacture, the country, the manufacturer, the stacking test load in kilograms and the maximum permissible gross mass in kilograms. A composite or rigid plastic IBC is also marked with the month and year of the last leakproofness test and the last inspection.
| Mark | What it tells you | Why a buyer or recycler cares |
|---|---|---|
| 31HA1 | Composite IBC, plastic bottle, steel cage | Confirms the tote can be rebottled or recycled in parts |
| X, Y or Z | The packing groups the design is approved for | Limits what the next fill can legally be |
| Manufacture date | Month and year the bottle was made | An old bottle is closer to the end of its life |
| Leakproofness test date | Month and year of the last test | A lapsed date means requalification before reuse |
| Inspection date | Month and year of the last inspection | Part of the retest cycle |
| Gross mass, stacking load | The limits in kilograms | Tells a mover how much a tote may carry and bear |
The retest cycle
Under 49 CFR 180.352, an IBC for liquids must pass a leakproofness test every 2.5 years from the date of manufacture or repair. It also needs an external visual inspection after production and every 2.5 years, and metal, rigid plastic and composite IBCs need an internal inspection at least every five years.
That cycle is why a used tote with an old date is not automatically a bad tote. It is one that needs the test again before it carries a regulated product. Reconditioned totes come with the test done. An as-is tote does not.
What the plate does not show
The plate does not record what the tote held. That information lives on the old product label and in the SDS, and the last-contents guide covers it. Keep both with the tote. A plate with every date current and no known last contents is a plate that still has to go through a check.
If the plate is missing, painted over or unreadable, the tote cannot be reused for a regulated product. It can still be recycled in parts: the bottle to regrind and the cage to steel.
Photographing the plate
Take the plate photograph in daylight, from straight on, with the plate wiped clean. Include the whole plate and a close-up of the dates. A blurred plate is as useless as no plate.
Keep reading
- ReconditionedA reconditioned tote is a used bottle and cage, both cleaned and certified. See what it takes to reach the grade and who buys it.
- Last contents and the SDSWhy the last contents decide a tote's next life, where to find them on the label or SDS, and what to send with a pickup request.
- Reconditioned and rebottledReconditioned and rebottled totes for repeat fills: what was cleaned, tested and replaced, and how to read the retest date.
Sources
- 49 CFR 178.702, IBC codes (Cornell LII)
- 49 CFR 178.703, IBC markings (Cornell LII)
- 49 CFR 180.352, IBC requalification and maintenance (Cornell LII)
Last reviewed . General guidance, not legal advice.