For electronics companies in the e-commerce retail market, coordinating consumer returns of batteries and other hazardous materials can be a nightmare.

Customers don’t know how to ship hazmat compliantly. In fact, they often don’t even know they’re shipping hazmat. And while recipients of non-compliant hazmat shipments (i.e., you) are not necessarily liable for mistakes made by other shippers (i.e., your customers), your company’s name and address are on the package.

You never want to see your products identified as the source of some sort of transportation incident. If a customer has a return shipment rejected, who are they going to blame? You.

That’s why you need to be a master of reverse logistics shipping.

If your products include Dangerous Goods, returns can also complicate your logistical planning because they’re subject to the same hazmat shipping regulations as your outgoing shipments. We’re talking about all those:

• Batteries and battery-powered devices

• Electronics

• Paints and coatings

• Perfumes

• Aerosols

• Cleaning solutions

• Smoke detectors

• Cosmetics

The good news? A new rule makes some return shipments easier for retailers with brick-and-mortar stores.

PHMSA HM-253 defines reverse logistics as “the process of offering for transport or transporting by motor vehicle goods from a retail store for return to their manufacturer, supplier, or distribution facility for the purpose of capturing value (e.g., to receive manufacturer’s credit), recall, replacement, recycling, or similar reason.”²

HM-253 applies ONLY to:

• Highway transport

• Limited quantity shipments

• Private carriers

HM-253 does NOT apply to:

• Air shipments

• Rail shipments

• Marine shipments

• Identify the hazardous materials in the shipment and verify compliance

• Provide clear handling and shipping instructions

• Ensure that the instructions are known and accessible to employees when they prepare the shipment

• Document that employees are familiar with the requirements

THE BAD NEWS? HM-253 does not apply to returns that come directly from consumers. Still, it’s the shipper’s responsibility to comply with hazmat transportation regulations—and, in the customer return scenario, the customer is the shipper.

How can you help customers ship returns compliantly?

Easy returns are an essential part of overall customer care. When developing your customer returns process, you should:

• Train customer service representatives on the basics of hazmat shipping so they can assist customers.

• Notify customers that rules exist, and give them guidance on the shipping requirements for the product being returned.

• Insist that all return shipments be made via ground shipping, since air transport is exponentially more complex.

• Consider sending customers packing materials and instructions.

• Consider sending customers replacement items and skipping the return process altogether. Be sure to provide the customer with information on the proper disposal of the items.

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¹National Retail Federation, Consumer Returns in the Retail Industry, 2014
²Federal Register, Vol. 81, No. 62. Thursday, March 31, 2016
³49 CFR Part 173.150–159, 306
⁴PHMSA Letter of Interpretation 09–0139

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Infographic | Your Guide to Retail Reverse Logistics