IBC ToteTexas

Reuse ledger, year to date: 41,200 totes diverted from Texas landfills this year. 2,060k lb of HDPE kept in service. 1,772k lb of steel cage recovered. 3,140 tons of CO₂e avoided. 92% of our wash water recycled on site. 68 Texas counties served from one Austin yard. Full methodology at /sustainability/reuse-ledger.

Guide · compliance

A plate is
not a certification.

Most of what gets sold as 'UN rated used totes' would not survive five minutes of scrutiny. This page sets out what the rules actually require, so you can tell the difference before a shipment rather than after one.

Flatbed trailer loaded with two rows of IBC totes secured with straps, hooked to a blue tractor unit

The short answer

To ship regulated liquid in an IBC, three things must be true at once: a valid UN marking (typically 31HA1/Y), a current retest — leakproofness every 2.5 years, full requalification every 5 — and any repair performed by a registered reconditioner. As the offeror you carry legal responsibility for verifying all three. None of this applies to storage on your own property.

Need compliant units?

Tell us the material and the packing group. We'll quote units with valid marking and current retest.

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From the yard

IBC totes strapped two high inside a box trailer with timber dunnage between the layers
Empties double-stacked and strapped over the cage rail — never over the bottle.
IBC totes staged on a port terminal apron beside stacked shipping containers and gantry cranes
Gulf Coast staging. The densest source of recoverable totes in North America.

First question

Does any of this apply to you?

A surprising number of people worry about UN compliance for containers that will never leave their own yard.

You need a compliant container when

  • The tote will travel on a public road containing a regulated material
  • You are offering the shipment to a carrier
  • Your customer's receiving requirements demand a UN-marked package
  • The material is classified hazardous under 49 CFR

You don’t when

  • The tote stays on your own property
  • You're storing water, fertilizer or non-regulated chemistry
  • The tote is used for irrigation, washout or jobsite water
  • The container is empty and being moved for reconditioning

Requirements

What the rules say

Simplified but not distorted. Read the actual sections before you make a compliance decision.

Key regulatory references
ReferenceCoversPractical effect
49 CFR 178.700–819IBC design qualification and testingDefines the design types and the tests a new IBC must pass to carry a UN marking
49 CFR 180.350–352Periodic retest, inspection and repair of IBCsLeakproofness every 2.5 years, full requalification every 5, test date marked on the unit
49 CFR 173.35Use of IBCs for hazardous materialsAuthorises IBCs for specified materials and sets conditions of use
49 CFR 107.501+Registration of packaging reconditioners and retestersOnly a registered facility may restore a UN marking after repair
49 CFR 172 Subparts C–FShipping papers, marking, labelling and placardingThe paperwork and markings that accompany the shipment itself
40 CFR 165.117(k)Pesticide container rinsing practiceThe triple-rinse practice our W2 standard follows

Retest

The intervals that quietly expire

In an unmanaged fleet, containers age out of compliance without anybody noticing until a shipment is refused.

Periodic testing under 49 CFR 180.352
IntervalRequirementScopeMarked on unit?
Every 2.5 yearsLeakproofness test and external inspectionContainment integrity, service equipment, marking legibilityYes — test date
Every 5 yearsFull requalificationLeakproofness plus internal and external inspection and structural verificationYes — test date
After any repairRetest before return to serviceAny repair affecting containment or structural equipmentYes
Before each useVisual check by the offerorDamage, leakage, marking legibility, retest currencyNo — but it's your obligation

Managed fleets track retest intervals against every unit so this never becomes a surprise →

Three questions to ask any seller of “UN rated” used totes

  1. What is your reconditioner registration number? Only a registered facility may restore a UN marking after repair. If they do not have one, they cannot have legitimately restored anything.
  2. What is the most recent test date marked on the container? If it is outside the retest window, the container is not authorised regardless of what the plate says.
  3. What repairs were performed, and were they retested? A repair without a subsequent test breaks the authorisation even if the work was competent.

A seller who answers all three specifically is selling compliance. A seller who deflects is selling you a risk that lands entirely on you, because the offeror carries the legal responsibility for the shipment.

The fuel question

We get asked constantly, so plainly: composite IBC totes are not an authorised packaging for transporting most fuels on public roads, and doing it anyway is a serious violation with real penalties. It is also genuinely dangerous — static, vapour and a 275-gallon plastic vessel are a poor combination.

Static storage of fuel on private property in a properly placarded, bonded, grounded and contained tote is a different question, governed by fire code and local requirements rather than DOT. Many operations do it lawfully. Check with your local authority having jurisdiction rather than with a forum.

What we do and don't provide

We supply UN-marked units where the marking is valid and the retest is current, primarily through rebottling, where requalification is handled as part of the work. We provide the test records and the registration details.

What we do not do is tell you that a given container is suitable for your specific regulated material. That determination involves chemical compatibility, packing group, quantity and your own shipping programme — it is the offeror's call, and any supplier who makes it for you is doing you no favours.

Questions people actually ask

+Can I ship regulated product in a used IBC tote?
Yes, if the container holds a valid UN marking, is inside its retest window, and any repair or reconditioning was performed by a registered facility. All three must be true simultaneously — and as the offeror, verifying that is your legal responsibility, not the seller's.
+How often does an IBC need retesting?
Leakproofness testing and external inspection every 2.5 years, and full requalification every 5 years, under 49 CFR 180.352. The most recent test date must be marked on the container.
+Can I transport fuel in an IBC tote?
Not on public roads in the general case — totes are not an authorised packaging for most fuel transport under DOT rules, and doing it anyway is a serious violation. Static storage on private property is a separate question governed by fire code and containment requirements.
+Does a used tote lose its UN rating automatically?
Not automatically, but practically often. The marking remains physically present; the authorisation depends on retest currency and on whether any repairs were done by a registered reconditioner. An unmarked test date or an unregistered repair breaks it.
+Who is legally responsible?
The offeror of the shipment — that's you. We supply containers, documentation and every fact we have. The determination that a specific container is suitable for a specific regulated material, on a specific day, is yours to make and yours to defend.

Related

Next

Quick reference

Numbers worth having open in another tab

The figures that come up in almost every conversation, whichever page you arrived on.

275 gallon · 1040 L

48×40×46

Tare
130 lb
Gross, water
2,425 lb
Stack full
2 high
Stock
Always in stock

330 gallon · 1250 L

48×40×53

Tare
160 lb
Gross, water
2,915 lb
Stack full
2 high
Stock
Always in stock

264 gallon · 1000 L

48×40×46

Tare
125 lb
Gross, water
2,325 lb
Stack full
2 high
Stock
Usually in stock

350 gallon · 1325 L

48×40×56

Tare
175 lb
Gross, water
3,095 lb
Stack full
2 high
Stock
Order in

Outlet thread

S60x6 — 60 mm coarse buttress. Not 2" NPT.

Grades published

N, R, F, A, B, C, X — applied at the wash bay.

Wash standards

W1 rinse through W4 caustic CIP at 160°F.

UN retest

Leakproofness 2.5 yrs, requalification 5 yrs.

From the yard notes

Longer reading on this

32 articles written by the people who wash, grade, weld and dispatch. No marketing copy in any of them.

All 32 articles

On the yard this week

Rows of used 275 gallon composite IBC totes stacked two high in an outdoor yard under a blue sky
Graded stock on the outdoor rows, stacked two high and waiting on a grade tag.
Outdoor tote yard beside a metal warehouse with the Texas flag flying overhead
The yard on a working Tuesday. Everything ships from one site in southeast Austin.

More answers

While you're here

Pulled from the full FAQ, which runs to forty-plus answers across buying, grades, food safety, sizes, selling, compliance, delivery and care.

Read the full FAQ

Where we are
3505 Montopolis Dr, Austin, TX 78744
Yard hours
Mon–Thu 7:30a–5p · Fri 7:30a–4p · Sat 8a–12p · Sun closed (Central Time)
Coverage
68 Texas counties on scheduled routes, from one Austin yard.

+What does 31HA1/Y mean?
Composite IBC for liquids (31), plastic inner receptacle (H), steel outer casing (A), category 1, approved for Packing Group II and III materials (Y).
+Who is responsible for compliance?
You are, as the offeror of the shipment. We supply containers and documentation; the determination that a given container is suitable for a given regulated material is yours. We'll give you every fact we have to make it.
+Does a used tote keep its UN rating?
Only if it was reconditioned by a registered facility, passed the required testing, and is inside its retest window. A UN plate on a rusty cage from an unregistered yard means nothing.
+How much does a used IBC tote cost?
Used composite IBCs in Texas run from the low hundreds for rough jobsite stock up to most of the price of a new unit for documented food-grade or rebottled containers. Grade moves the price more than anything else — often by a factor of four across the same size.
+Can I clean a tote myself?
For non-critical uses, yes — a proper three-stage rinse with agitation and full drain between stages does a lot. For food service, no: you need documented parameters and a caustic clean-in-place, which is what our W4 standard is for.

Send the material and the packing group.

That plus quantity is enough for us to quote units with valid marking and current retest — or to tell you honestly that you need new containers.

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