Proposed amendments to Item 640 and Item 680 would fundamentally change how carriers rate mixed commodity LTL shipments, and what shippers must do to stay compliant.
The National Motor Freight Traffic Association Inc® (NMFTA™)1 has proposed significant amendments to two foundational rules governing how less-than-truckload (LTL) freight is classified and rated when multiple commodity types share a single shipment or pallet. If adopted, these changes will affect nearly every shipper moving mixed-commodity freight.
The proposed revisions target Item 640 Mixed Shipments and Articles Classified by Weight or Quantity and include a new packaging provision under Item 680, Packing or Packaging. Both items appear in the National Motor Freight Classification (NMFC®), the industry’s standard reference for freight class determination.
What Is the Mixed Freight Rule?
When a shipper tenders a single shipment containing multiple commodities, say, plastic parts with bags of sand, each commodity may carry a different NMFC freight class. The question of how to rate that combined load has historically created ambiguity between shippers and carriers.
Item 640 is the rule that answers that question. The proposed amendment rewrites it with greater precision, and introduces a tiered inspection-based rating framework
Breaking Down the Proposed Changes to Item 640
If the proposed amendments to Item 640 are adopted, shippers moving mixed-commodity LTL freight will face a significantly higher documentation burden the moment freight leaves the dock. Describe each handling unit on a mixed shipment individually on the bill of lading, including commodity, class, and weight. Vague or consolidated BOL descriptions will no longer offer protection against reclassification.
Carriers who inspect a shipment and find inaccurate data can rerate the entire load under the 13-subprovision density scale. They may calculate density per handling unit or across the total shipment cube. Shippers who provide accurate weights and dimensions on the original BOL keep more control over the outcome. However, this only applies if the data passes carrier verification. The practical message is clear: inaccurate paperwork when routing mixed articles is no longer going to be allowed to slip through, under these rules, it becomes a direct cost exposure.
Section 1: Single-Class Shipments (No Change in Effect)
Item 640 · Sec. 1
A single-class shipment continues to be assessed at its actual or authorized estimated weight and applicable class, subject to any minimum charge in the carrier’s tariff. This section is largely confirmatory.
Section 2: Multi-Class Shipments: Bill of Lading Requirements Tighten
Item 640 · Sec. 2
This is where shippers must pay close attention. When a single shipment contains articles subject to two or more classes, the bill of lading must now specify:
- Each article, listed separately by class
- The total weight of each separately classified article
Critically, differently classified articles, even those in separate handling units, will be assessed at the actual or estimated weight and class applicable to each individual handling unit. This reinforces the importance of accurate, itemized documentation at the handling-unit level.
Key Takeaway:
Vague or consolidated bill of lading descriptions for mixed-commodity pallets will no longer hold up, and will be subject to reclassification. Carriers gain explicit authority to reclassify based on inspection.
Section 3(a): Inspection Triggers a Density Based Option
Item 640 · Sec. 3(a)
If a shipment is inspected and the bill of lading is found to inaccurately describe articles and freight classes, or if the shipment contains density-based classifications within the same handling unit, the carrier gains the option to classify the entire shipment using the 13-subprovision density scale published in the Classification.
If the shipper provided weight and dimensions for each handling unit on the original bill of lading, those figures will be used for density calculation pending carrier verification. However, if the bill of lading lacks accurate data, the carrier may calculate density using total shipment weight and cube. Alternatively, the carrier may calculate it per handling unit at their discretion.
Section 3(b): Non-Density Articles Trigger Highest-Class Assessment
The rule as written creates a significant cost concern. A single specialty-classed or hazmat article, even if it represents a tiny fraction of the shipment’s weight or value, can pull the entire pallet’s rating up to the highest class present. Shippers should audit their pallet configurations now. The practical defense is simple: segregate. Keep non-density-rated freight, hazmat, and high-liability articles on their own dedicated handling units whenever operationally possible. The cost of an extra pallet almost always beats the cost of a full-shipment reclassification at Class 300 or 400.
Item 640 · Sec. 3(b)
When not all articles have density-based classifications, or when any article has handling, stowability, or liability considerations, is a regulated hazardous material, or is classified by packaging type, greatest dimension, or another factor the carrier reserves the right to assess the entire shipment at the highest class of any article tendered.
Under proposed Section 3(b), if even a single article on a pallet is classified by handling, stowability, liability, packaging type, or hazardous material status rather than density, the carrier can assess the entire shipment at the highest class present, regardless of what everything else on that pallet is worth or weighs. Additionally, Section 3(c) below adds a liability concern that shippers should be careful to not overlook: any article subject to released value provisions in the NMFC at the time of shipment will be considered released at the lowest stated release value, no exceptions.
Section 3(c): Released Value Provisions Preserved
Item 640 · Sec. 3(c)
Regardless of class, any article subject to released value provisions under the NMFC at the time of shipment shall be considered released at the lowest stated release value.
This matters in claims scenarios. Shippers who assume full protection may find recovery capped far below expectations. To reduce risk, follow Sections 3(b) and (c). Segregate freight when possible. Keep high-class, hazmat, and specialty items on dedicated pallets. Also, review released value provisions for each commodity type before shipment.
Section 4: Pallet Weight Must Be Declared and Will Be Rated
This is one of the most overlooked provisions in the proposal and has the potential to catch shippers off guard at scale. Tare weight, the weight of the pallet, skid, shrink wrap, strapping, corner boards has often been absorbed or ignored on the BOL. Likewise, the weight was added into the overall shipment parameters, or there was a negotiated reweigh variance that this could fall under.
Under this rule proposal, it must be declared, and it will be rated. The good news for shippers is that it’s assessed at the lowest class of any article making up at least 5% of the unitized weight. However, it only applies if the BOL is accurate. Shippers who don’t have a process for capturing and documenting tare weight need to build one. If this rule were to proceed forward, shippers would need to potentially change their packing processes.
Start by weighing empty pallets and packaging materials. Then add this step to your pick and pack workflow. Finally, make sure your warehouse teams understand that missing pallet weights create a compliance gap.
Item 640 · Sec. 4
The weight of pallets, platforms, racks, skids, unitizing materials, or packaging forms as required by Item 680 must be shown on shipping orders and bills of lading. That weight will be assessed at the lowest class applicable to any article comprising at least 5% of the total unitized weight on the pallet or skid.
What’s New in Item 680: Packing & Packaging
The proposed amendment adds a new Section 18 to Item 680. Sections 1–17 remain unchanged.
Item 680 · Sec. 18 (New)
Articles tendered in a fiberboard box secured to a pallet, platform, skid, or rack must include interior packaging forms in the unoccupied space between articles or inner packages and the inside top of the outer box. These interior forms must be of sufficient strength and design to prevent collapse of the outer box when freight is loaded on top.
This provision sounds straightforward until you realize it applies broadly to any fiberboard box on a pallet, which describes a vast amount of LTL shipments. The burden falls entirely on the shipper now to ensure void fill is present and structurally sufficient to prevent top-load collapse. This is ideal in theory as the amount of cargo claims would drop, but this would require consistent packaging changes, and broader market awareness that this is now necessary. Carriers could use this as a basis to reclassify or refuse freight at pickup. If this rule were to go into effect, shippers should update their packing SOPs now. Likewise, shippers should plan for the void-fill materials used, and consider noting interior packaging compliance on the bill of lading or packing slip. While not necessary it may help prevent and avoid disputes downstream. What was once a best practice is now a proposed classification requirement.
This new section reinforces structural integrity requirements for palletized fiberboard shipments. This is a direct response to cargo damage and stowability concerns that arise when boxes are not internally supported.
Why This Matters for Shippers and Carriers
These proposed changes represent one of the most operationally significant updates to mixed-freight classification rules in recent years. The practical implications are broad:
- Shippers must document mixed pallets with greater precision. Itemize each handling unit’s commodity, class, and weight on the bill of lading. Do not consolidate or generalize them.
- Carriers gain a clearer inspection-and-reclassification framework. The tiered structure in Section 3 reduces disputes by establishing explicit pathways depending on what inspectors find.
- Density becomes the fallback rating method for mixed density-class shipments. Provide accurate cube and weight data for each handling unit to control how carriers calculate density.
- Hazmat, high-liability, and specialty class articles trigger a worst-case assessment. Even one non-density-rated item can drive the entire shipment to the highest class. When possible, it’s best to separate non-density-rated freight onto its own pallet to avoid increasing the overall shipment cost.
- Packaging integrity is now a classification consideration. The new Item 680 Section 18 ties physical packing standards directly into classification compliance.
How to Submit Feedback to the FCDC
For shippers wanting to review all existing NMFC rules and stay current on proposed changes, the authoritative source is the NMFTA™ at https://nmfta.org/nmfc/standards/
The NMFTA™ is actively seeking industry input on these proposed amendments through the Freight Classification Development Center (FCDC). Shippers, carriers, logistics professionals, and industry associations are encouraged to weigh in before the comment period closes.2
Submit Your Feedback:
- Option 1 – Online Form: Complete the online submission form at nmfta.org
- Option 2 – Email: Send your comments to fcdc@nmfta.org
- Option 3 – Postal Mail: Write to the FCDC directly via the postal service:
- Mail to Address:
Freight Classification Development Center
1001 North Fairfax Street, Suite 600
Alexandria, VA 22314
- Mail to Address:
- NMFTA™ and National Motor Freight Traffic Association Inc® are trademarks of the National Motor Freight Traffic Association, Inc. NMFC® is a registered trademark. This article is intended for informational purposes only and does not constitute legal or tariff advice. Always consult the current NMFC and your carrier’s tariff for classification guidance. ↩︎
- In response to these concerns, I submitted formal feedback to the Freight Classification Development Center at fcdc@nmfta.org raising the operational burdens this would have on shippers. I gently encourage other shippers and logistics professionals to do the same before the comment period closes. ↩︎
