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Tote retest dates

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. Hazmat shippers check the retest date on the plate before they check anything else.

UN 31HA1/Y Made: month / yearLast leak test: month / yearLast inspection: month / yearStacking load: kgMax gross mass: kg

2.5 YR

The test and the inspection

The leakproofness test is every 2.5 years from manufacture or repair. An external visual inspection is required after production and every 2.5 years too. Metal, rigid plastic and composite IBCs also need an internal inspection at least every five years.

The plate carries the month and year of the last test and the last inspection. That is the date the shipper reads.

IBC test and inspection intervals
CheckIntervalApplies to
Leakproofness testEvery 2.5 yearsIBCs for liquids
External visual inspectionAfter production and every 2.5 yearsIBCs
Internal inspectionAt least every 5 yearsMetal, rigid plastic and composite IBCs

What it means for a used tote

A used tote with a lapsed retest date is not necessarily a bad tote. It is a tote that cannot go back into hazmat service until it is retested. For a grower using it as a water tank or a warehouse using it to hold dry goods, the date does not matter. For a blender shipping a hazardous liquid, it is the first check.

That is why reconditioned totes carry a certificate. See reconditioned totes. The 2.5 year clock restarts with the test.

Before you buy or ship

  • Read the date on the plate. Not on a sticker; on the plate.
  • Count 2.5 years from the test, not the manufacture date, if a test has been done.
  • Ask for the certificate for a reconditioned tote.
  • If you are not shipping hazmat, ask the carrier what they need.

A date arithmetic example

Suppose the plate shows a leakproofness test in March 2025. Two and a half years later is September 2027, so the tote is inside its window until then. A tote tested in March 2023 expired in September 2025, and it would need a new test before it carried a regulated liquid again, however good it looks.

Manufacture dates work the same way when no test has been recorded. The clock starts from manufacture or the last repair, whichever is later, and the plate is the record. If the plate is unreadable the date is unknown, and an unknown date is treated as expired.

A tote that will only ever hold water on a farm never ships under these rules, so the date there is a quality hint rather than a legal limit.

Where a test date is written

On a composite IBC the test month and year appear on the plate and sometimes on the bottle itself. If the dates differ, the earlier governs the whole assembly.

Who performs the test

Tests are done by qualified reconditioners and test facilities, and they record the result on the plate. Ask who did the last one.

Retest and resale

A tote with a fresh test date is easier to sell and to ship. If you hold a lot with dates close to expiry, mention it, because a buyer who needs hazmat service will plan the retest into the price.

A date well inside its window is a selling point; a lapsed date is a cost to the next owner.

Questions people ask

How often does an IBC tote need to be retested?

A leakproofness test every 2.5 years from manufacture or repair, for liquids.

Does the rule apply to a tote used for water?

It applies to IBCs for liquids in transport. A water tote that never ships is not covered the same way.

Sources. Last reviewed 2026-11-11.

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