Household Goods Authority: The Extra Filings

HHG authority is not van freight with furniture

Household goods, in the federal sense, are the contents of a dwelling shipped for an individual householder under a defined commercial relationship. They are not a pallet of boxed furniture moving as general freight for a retailer, and they are not your cousin's couch on a favor. If you are holding out to the public to move households, you need HHG operating authority. A general-freight property grant does not authorize that service.

Carriers get this wrong in both directions. A mover with only a general-freight MC loads a residence and hopes the bill of lading looks like a dock shipment. An HHG applicant tries to run ordinary pallet freight and skip the cargo form. Authority type follows the transportation you actually sell. Pick the type before you pay the $300, because each type is its own fee and its own filing set.

This is not a startup guide to buying pads and a dollies, and it is not a city directory of movers. The operational question is which extra filings sit on top of a normal property application. The application mechanics are how to get MC authority. Stay here for the HHG extras.

Cargo filing: form, per-vehicle, and aggregate

FMCSA requires HHG cargo insurance on the prescribed cargo form. Confirming the current chart: the certificate of insurance for household-goods cargo liability is BMC-34, filed by the insurer. The endorsement for cargo liability policies is BMC-32, which the insurer attaches to the policy and which is part of an aggregated filing when more than one insurer participates. The surety alternative is BMC-83. FMCSA's public FAQ on insurance forms states that BMC-34 is how HHG cargo insurance is filed and that the agency does not hand you the blank; the insurer keeps it.

The long-standing floor is still the floor in the current 49 CFR 387.303(c). For loss of or damage to household goods carried on any one motor vehicle, security is $5,000. For loss or damage, or the aggregate of losses or damages, occurring at any one time and place, security is $10,000. Quote those two numbers from that subsection. Do not replace them with a broker's $100,000 cargo schedule. A shipper or a van line can contract for more. The federal filing floor is the regulation.

Ordinary general-freight carriers do not file this cargo form. If your application is HHG, cargo is not optional. If your agent only knows BMC-91, they are filing liability and forgetting the cargo certificate. Both have to be on the docket. You still cannot transmit them yourself.

The arbitration offer under 49 USC 14708

49 U.S.C. 14708 requires household-goods motor carriers to offer shippers arbitration as a way to resolve disputes about loss and damage to the household goods. FMCSA's application confirmation calls this program out by name because it is a condition of holding yourself out as an HHG carrier, not a paragraph your lawyer might add later if a claim goes badly.

Arbitration here is a statutory dispute path for individual shippers. It is not the same clause a broker pastes into a carrier packet, and it is not a waiver of the cargo filing. You can meet 14708 and still have a BMC-34 reject. You can have a perfect BMC-34 and still violate the arbitration rules if you never actually offer the program the statute describes.

Read the statute and FMCSA's HHG consumer materials before you print a claim form. Do not copy a general-freight cargo claim policy and retitle it. The timelines, the written disclosures, and the arbitration notice are HHG-specific. This page names the duty. It does not reprint the consumer pamphlet.

Tariff and estimate rules that general freight does not have

HHG transportation of individual shippers comes with estimate, order-for-service, and inventory practices that a general-freight rate confirmation does not contain. Underestimates, fees for services you did not perform, and weight tickets that do not match the reweigh are their own violation family in the commercial rules. Appendix B to Part 386 sets minimum penalties for HHG estimate and weight abuses that a dry-van carrier never sees. Look up the current appendix before you quote a dollar, because those lines adjust.

A written estimate is not a suggestion. Charging above it without the rights the rules give you, or collecting for accessorials you did not disclose, is how HHG carriers meet investigators. General freight lives on a rate confirmation and a bill of lading. Do not import that looseness into a residence move.

If you are an agent for a van line, the van line's tariff and your own authority can be two different legal facts. Know which MC is on the estimate. Operating under their authority is not the same as holding HHG authority yourself. Operating under yours without the filings is the violation this page is about.

Why HHG draws more protests

The 10-day protest in 49 CFR 365.115 matters more here than on a plain property application. Existing movers watch the FMCSA Register for new HHG applicants. Fitness, ownership, and whether you are a new name on an old failed mover are the usual themes. A clean one-truck dry van is rarely protested. An HHG application should budget time for the chance that someone files.

A protest is not cured by calling FMCSA or by paying another fee. The response has to meet the merits. If you have a prior revocation or common control with a mover that was shut down, disclose it on the application. Hiding it is a false filing, and it is the fact a protestant will lead with.

Do not scare yourself into delaying a legitimate application, and do not assume silence. Watch the Register date, count 10 calendar days, and do not book a household until authority is ACTIVE and both the liability and cargo filings show. The timeline habits on a normal grant are the same clocks, with a higher chance someone uses them.

Insurance limits versus a general-freight $750,000 filing

The $750,000 BIPD floor still applies to for-hire property carriage at the weights in 49 CFR 387.9. HHG does not get a discount on liability, and liability does not replace the cargo filing. Your docket needs the auto liability certificate at the schedule amount and the BMC-34 (or BMC-83) at the 387.303(c) amounts. Brokers and van lines often ask for cargo limits far above $5,000 and $10,000. Those requests are contracts. Meet the contract if you want the load, and meet the regulation if you want the authority to stay in force.

A certificate you email to a customer is not the filing. The insurer transmits BMC-91 or BMC-91X and BMC-34. Name mismatches reject HHG filings the same way they reject general freight. Use the legal name on the application.

Passenger limits and hazmat schedules are different tables. Do not let an agent price you as a bus or as a gasoline tanker because the goods are household. Price the operation you filed. Then stop adding services the grant does not include.

What to verify before you act

Build a one-page HHG filing checklist and do not load a residence until every line is yes. Authority type on the application is household goods, not general freight with a note. Auto liability filing posted at the property floor that applies to you. BMC-34 or BMC-83 posted at the $5,000 and $10,000 floors in 49 CFR 387.303(c). Arbitration program actually offered, not just mentioned in a slogan. Estimates and inventories use the HHG rules, not a broker rate confirmation with the word furniture typed on it.

If you are an agent for a van line, ask which MC is on the estimate the customer signs. Their authority is not your authority. Your new HHG grant, once ACTIVE, is what you may use only when you are the carrier. Mixing the two on one job is how a claim lands on a docket that was never filed.

Budget the protest window as real time, not as a scare. Check the Register date, count ten calendar days, and do not market a move for the day after you pay. A competitor can file. A clean property carrier usually will not face that. You might. The extra filings are the point of this authority type. General freight never had them, which is why a general-freight MC cannot quietly become a mover.

Frequently Asked Questions