Empty IBCs shipped for reconditioning must have labels intact that identify the material last contained – this requirement is for safety in transportation and safety in the workplace at the reconditioner.  Regulations requiring product labels on empty IBCs are listed below:

DOT Regulation 49 CFR 172.302 (d):

Each bulk packaging marked with a proper shipping name, common name or identification number as required by this subpart must remain marked when it is emptied unless it is –

(1) Sufficiently cleaned of residue and purged of vapors to remove any potential hazard;
or
(2) Refilled, with a material requiring different markings or no markings, to such an extent that any residue remaining in the packaging is no longer hazardous.

OSHA Regulation 29 CFR 1910.1201(a):

Any employer who receives a package of hazardous material which is required to be marked, labeled or placarded in accordance with the U. S. Department of Transportation’s Hazardous Materials Regulations (49 CFR Parts 171 through 180) shall retain those markings, labels and placards on the package until the packaging is sufficiently cleaned of residue and purged of vapors to remove any potential hazards.