Buyers who have not moved nicotine before tend to meet the dangerous goods paperwork at the worst possible moment, which is usually when a first order is already booked and a forwarder starts asking questions nobody has the answers to.
None of it is difficult. It is just specific, and most of it is decided by which form of nicotine is on the purchase order rather than by anything about the shipment itself.
A scope note before the detail. What follows is the United States Hazardous Materials Regulations, at 49 CFR, which govern transport in US commerce (49 CFR 172.101). Air, sea and non-US movements run on separate rule sets, and the applicable one for a given lane is a question for the carrier or forwarder handling it. Nothing here is a substitute for that conversation.
What UN 1654 Is
In the Hazardous Materials Table, the proper shipping name "Nicotine" is assigned hazard class 6.1, identification number UN1654, and Packing Group II, with a 6.1 label (49 CFR 172.101).
Class 6.1 is the toxic class, and Packing Group II sits in the middle of the three packing groups, which run from I for the greatest danger to III for the least (49 CFR 172.101). The practical meaning of a packing group is that it drives which packagings are authorized and what quantity limits apply, so it is not a label detail. It is an input to how the material can physically travel.
That entry is the one behind the UN 1654 and Class 6.1 designations shown against pure nicotine on our pure nicotine USP and EP page. Worth separating from the CAS number, which identifies the substance chemically and is not a transport classification.
The Form You Buy Decides the Entry
There is no single nicotine entry that covers everything a manufacturer might buy. The table lists the named salts separately, and it distinguishes solid from liquid forms of the same salt (49 CFR 172.101).
The nicotine entries in the table, with their class, identification number and packing group (49 CFR 172.101):
| Proper shipping name | Class | ID number | PG |
|---|---|---|---|
| Nicotine | 6.1 | UN1654 | II |
| Nicotine compounds, liquid, n.o.s. or Nicotine preparations, liquid, n.o.s. | 6.1 | UN3144 | I |
| Nicotine compounds, solid, n.o.s. or Nicotine preparations, solid, n.o.s. | 6.1 | UN1655 | I |
| Nicotine hydrochloride liquid or solution | 6.1 | UN1656 | II |
| Nicotine hydrochloride, solid | 6.1 | UN3444 | II |
| Nicotine salicylate | 6.1 | UN1657 | II |
| Nicotine sulfate solution | 6.1 | UN1658 | II |
| Nicotine sulphate, solid | 6.1 | UN3445 | II |
| Nicotine tartrate | 6.1 | UN1659 | II |
Note what the solid and liquid split does. Nicotine sulphate as a solid is UN3445, while nicotine sulfate solution is UN1658 (49 CFR 172.101). Same salt, different entries. A specification change that moves a material between those states changes the shipping description, and the sulphate forms have their own commercial and regulatory history, covered in nicotine sulphate in agriculture.
The Generic Entries Are Stricter, Not Looser
The two generic entries are the ones worth understanding before a first shipment, because the intuition about them is usually backwards.
Nicotine compounds or preparations, liquid, n.o.s. is UN3144, and the solid equivalent is UN1655. Both are assigned Packing Group I (49 CFR 172.101). That is the most restrictive packing group, and it is stricter than the Packing Group II assigned to pure Nicotine (49 CFR 172.101). Falling into a generic description is not a lighter-touch outcome.
Both generic entries also carry the letter G in the table's first column. The table's own explanation is that "The letter 'G' identifies proper shipping names for which one or more technical names of the hazardous material must be entered in parentheses, in association with the basic description" (49 CFR 172.101). The corresponding rule states that unless otherwise excepted, where a material is described by one of those names, "the technical name of the hazardous material must be entered in parentheses in association with the basic description" (49 CFR 172.203(k)).
So a preparation shipped under a generic entry needs its technical name written into the description. Whether a given material belongs under a named entry or a generic one is a classification decision, and it is the shipper's to make, informed by what the supplier's documentation actually says the material is. Formulated dilutions are the usual place this question arises, and the carrier side of it is worth raising alongside the formulation choice discussed in choosing a carrier for e-liquid dilutions.
The Reportable Quantity Is Lower Than People Expect
This is the requirement most often discovered late.
Appendix A to the Hazardous Materials Table lists "Nicotine, & salts" with a reportable quantity of 100 pounds, given as 45.4 kilograms (49 CFR 172.101).
That number matters because of how the regulations define a hazardous substance. The definition covers a material, including its mixtures and solutions, that is listed in that appendix and "Is in a quantity, in one package, which equals or exceeds the reportable quantity (RQ)", with an additional condition for mixtures and solutions that the material be "in a concentration by weight which equals or exceeds the concentration corresponding to the RQ of the material" (49 CFR 171.8). For a reportable quantity of 100 pounds, the corresponding concentration in that section's table is 0.2 percent by weight, or 2,000 ppm (49 CFR 171.8).
Read the test carefully, because two details do the work. It is a quantity in one package, not a quantity per shipment, so consolidating or splitting changes the answer. And for a solution, both conditions have to be met, the quantity and the concentration.
When a shipment does meet the definition, two things follow. The letters RQ must be entered on the shipping paper either before or after the basic description, for each hazardous substance (49 CFR 172.203(c)). And for a non-bulk package, where the proper shipping name does not identify the hazardous substance by name, that name must be marked on the package in parentheses in association with the proper shipping name (49 CFR 172.324).
The arithmetic is worth doing for each pack size on a quotation rather than assumed once for an account.
Two Requirements That Trip a First Shipment
Two obligations sit with the party offering the material for transport, and neither can be quietly delegated to a forwarder.
The first is the emergency response telephone number. A person offering a hazardous material for transportation must provide a numeric emergency response telephone number including the area code, and that number must be "Monitored at all times the hazardous material is in transportation, including storage incidental to transportation" and must be the number of someone knowledgeable about the material with comprehensive emergency response and incident mitigation information, or with immediate access to such a person (49 CFR 172.604). The section then closes the obvious workaround: "A telephone number that requires a call back (such as an answering service, answering machine, or beeper device) does not meet the requirements" (49 CFR 172.604). An office line that goes to voicemail outside business hours is not compliant, and a shipment that sits in a terminal over a weekend is still in transportation.
The second is training. Hazmat employee training is a recurring obligation, not a one-time onboarding item: "A hazmat employee must receive the training required by this subpart at least once every three years" (49 CFR 172.704). The definition of a hazmat employee reaches people who load, unload or handle hazardous materials, and those who prepare them for transportation (49 CFR 171.8), which in a small operation is often someone who does several other jobs as well.
What to Confirm Before the First Shipment
A short list, each item tied to a requirement above rather than to general practice.
- The proper shipping name, identification number, class and packing group for the exact form you are buying, checked against the table rather than carried over from a previous material (49 CFR 172.101).
- Whether the material falls under a named entry or a generic one, and if generic, the technical name that has to appear in parentheses (49 CFR 172.203(k)).
- The nicotine content per package against the 45.4 kilogram reportable quantity, and for a solution, the concentration against 0.2 percent by weight (49 CFR 172.101, 49 CFR 171.8).
- Who provides the emergency response telephone number, and whether it is genuinely monitored while the goods are in transportation including storage incidental to it (49 CFR 172.604).
- Which named individuals have current hazmat training and when their three-year cycle next falls due (49 CFR 172.704).
- For any movement by air or sea, or outside the United States, which rule set the carrier is applying, since this section of the regulations does not govern those lanes.
Most of the first three are answered by the material's own documentation. A safety data sheet carries the transport classification, and a specification establishes what the material actually is, which is what a classification decision rests on. Our technical documents library lists specifications, methods of analysis and safety data by product and document type, and the nicotine dilutions page sets out the forms where the named-versus-generic question comes up most often. If a first shipment is being planned, the useful sequence is to settle the classification from the documentation before the freight is booked, rather than after.
Frequently Asked Questions
What UN number and packing group does pure nicotine ship under?
In the Hazardous Materials Table at 49 CFR 172.101, the proper shipping name Nicotine is assigned hazard class 6.1, identification number UN1654 and Packing Group II, with a 6.1 label. Class 6.1 is the toxic class, and the packing group drives which packagings are authorized and what quantity limits apply. This is the US classification under the Hazardous Materials Regulations; air, sea and non-US movements are governed by other rule sets.
Does a nicotine solution ship under UN 1654?
Not necessarily, because the table lists several nicotine entries and the right one depends on the material. 49 CFR 172.101 gives nicotine hydrochloride liquid or solution UN1656 and nicotine sulfate solution UN1658, while nicotine compounds or preparations, liquid, n.o.s. is UN3144 and is assigned Packing Group I rather than the Packing Group II assigned to Nicotine. Classification is the shipper's decision and should be made from what the material actually is, not from the entry used for a previous product.
When does a nicotine shipment count as a hazardous substance requiring an RQ entry?
Appendix A to 49 CFR 172.101 lists Nicotine and salts with a reportable quantity of 100 pounds, or 45.4 kilograms. Under the definition at 49 CFR 171.8, the material is a hazardous substance when the quantity in one package equals or exceeds that reportable quantity, and for a mixture or solution when the concentration by weight also equals or exceeds the corresponding figure, which for a 100 pound reportable quantity is 0.2 percent. Where it applies, 49 CFR 172.203 requires the letters RQ on the shipping paper before or after the basic description.
Who has to have hazmat training, the supplier or the freight forwarder?
The obligation attaches to hazmat employees, which covers people who classify material, prepare shipping papers or handle packages, so it can apply on both sides of a transaction rather than sitting with one party. Under 49 CFR 172.704 a hazmat employee must receive the required training at least once every three years, making it a recurring obligation rather than a one-time induction. It is worth confirming who on your own staff falls within scope before assuming a forwarder's training covers your role.