Retest dates and recertification
A tote used to ship hazardous materials must be tested and inspected on a schedule set in 49 CFR 180.352: a leakproofness test and external inspection every 2.5 years and a fuller inspection every 5 years. Totes used for water, rain or irrigation have no such requirement.
Last reviewed November 11, 2026
The cycles
| Check | How often (hazmat service) |
|---|---|
| External visual inspection and leakproofness test | Every 2.5 years |
| Internal inspection and fuller test | Every 5 years |
The details depend on the type of tote and the product. Read the regulation or ask the reconditioner.
What the retest date tells you
The plate or a marker near it records the date and the type of the last test. Add 2.5 years to see when the next is due. An expired mark does not make the tote useless; it makes it unfit for hazmat service until retested.
Who does it
A reconditioner or an approved testing facility performs the test and applies the mark. A buyer who needs a certified tote should ask for the date and keep a copy of the paperwork.
If you are not shipping hazmat
Growers, households and rain harvesters usually never ship hazardous materials, and the retest rule does not apply. Even so, a current mark is a sign the tote has been looked at recently, and it counts when a grade is set.
In South Florida
Totes that travel on ships and trucks across state and national lines are checked at the plate, so the plate and the retest mark are what a carrier, a customer or an inspector looks at first. A grower buying a tote for irrigation can ignore the cycle, but an importer refilling a tote with a regulated ingredient cannot. If you are not sure which group you are in, ask the product supplier.
Questions to ask a reconditioner
When you buy a certified tote, ask who performed the test, whether it was a leakproofness test only or a fuller inspection, what date is stamped, and what type of tote it applied to. Ask what was replaced: gasket, valve, cap, bottle. Ask for a copy of the record. A reputable reconditioner will answer in a minute and send a photo of the marks. If the answer is vague, treat the tote as uncertified, and use it for water, irrigation or storage where no regulated product is involved. Keep the paperwork with the tote and with your own records, because an auditor, an insurer or a customer may ask for it later, and a missing record is the same as no test at all.
Why a missing mark matters
A tote with no later mark on its plate may be new, may be overdue or may never have been retested. For a regulated product, treat it as overdue. For rain, irrigation or storage of non-regulated liquid, it does not matter. Always record what you see on the day you buy.
Questions people ask
Does a missing mark mean a bad tote?
Not necessarily; it means unverified.
What should I record?
The plate, the marks and the date.
What should a test record show?
Date, test type, tester and what was replaced.
Can I retest my own tote?
Only an approved facility can apply the mark.
Who keeps the retest records?
The owner of the tote and the facility that tested it. Keep a copy with your records.
What happens if a mark is overdue?
The tote is not to be filled with a regulated product until it is retested.
How often is a retest?
Every 2.5 years for leakproofness and inspection.
And the internal inspection?
Every 5 years.
Do I need it for water?
No.
Who tests?
A reconditioner or approved facility.
Where is the mark?
On or near the plate.
Ask about retests
Tell us the plate date.