Hazardous Materials Import and Export Customs Clearance Guide: Compliant Operations, Safe Trade
Created on 07.29
In today's closely interconnected global economy, the import and export of hazardous chemicals injects vitality into the development of numerous industries. However, due to their flammable, explosive, and toxic characteristics, hazardous chemicals pose risks during transportation and storage, and a slight misstep can lead to serious safety accidents. Therefore, ensuring the smooth customs clearance and safe circulation of hazardous chemicals is crucial. Enterprises must strictly adhere to relevant regulatory requirements and control every link in the process. This article will take you in-depth to understand the key points of customs clearance for hazardous chemicals import and export, helping you to conduct trade in compliance.
(Image source: Official WeChat account of Chongqing Customs)
Clarification of Basic Concepts of Hazardous Chemicals
1) Hazardous Chemicals
According to the "Regulations on the Safety Management of Hazardous Chemicals" (State Council Order No. 591), hazardous chemicals refer to highly toxic chemicals and other chemicals that possess properties such as toxicity, corrosion, explosion, combustion, and support for combustion, which can cause harm to human beings, facilities, and the environment. In simple terms, products listed in the "Catalog of Hazardous Chemicals" are considered hazardous chemicals. Their hazardous characteristics are divided into three major categories: physical hazards, health hazards, and environmental hazards, totaling 29 items. It should be noted that civilian explosives, fireworks, radioactive materials, nuclear materials, and hazardous chemicals used for national defense scientific research and production are not applicable to this regulation. Moreover, in the classification principles of hazardous chemicals, some chronic hazards that harm health and the environment have not been adopted by the classification standards for dangerous goods. For example, boric acid, although classified as a hazardous chemical, does not fall under the category of dangerous goods.
2) Dangerous Goods
According to the "Classification and Coding of Dangerous Goods" (GB 6944 - 2012), dangerous goods refer to substances and items that have dangerous characteristics such as explosion, flammability, toxicity, infection, corrosion, and radioactivity, which can easily lead to personal injury, property damage, or environmental pollution during transportation, storage, production, operation, use, and disposal, and therefore require special protection. It is divided into 9 major categories: explosives, gases, flammable liquids, flammable solids, oxidizing substances, toxic substances, radioactive substances, corrosive substances, and miscellaneous dangerous goods. It is worth noting that the concepts of dangerous goods and hazardous chemicals are different; dangerous goods are not necessarily hazardous chemicals, such as lithium batteries and automotive airbags.
3) Dangerous Goods Packaging
Dangerous goods packaging refers to packaging containers that hold dangerous goods, typically covering packaging containers with a capacity not exceeding 450 liters and a net weight not greater than 400 kilograms, medium bulk containers, large containers (big packages), etc. In addition, it also includes pressure vessels, aerosol cans, and small gas containers, portable tanks, and multi-gas containers, etc. It is particularly important to note that export dangerous goods packaging must undergo customs performance inspection and usage certification to ensure compliance with international transportation standards.
（Image source: Official WeChat account of Chongqing Customs）
Regulatory requirements for the import and export of hazardous chemicals
1) Imported hazardous chemicals
According to the "Announcement on Issues Related to the Inspection and Supervision of Import and Export Dangerous Chemicals and Their Packaging," the consignee or agent of imported dangerous chemicals shall truthfully fill in the attributes of the goods, inspection and quarantine names, danger categories, packaging categories, United Nations Dangerous Goods Number (UN Number), dangerous goods packaging marks (Packaging UN Mark), and destination inspection customs information when declaring customs, and shall upload and submit the following materials separately according to the declared goods:
- Import Dangerous Chemicals Enterprise Compliance Declaration
- For products that require the addition of inhibitors or stabilizers, it is necessary to provide details such as the actual names and quantities of the inhibitors or stabilizers added.
- Chinese Danger Label (excluding bulk products), sample of Chinese Safety Data Sheet
2) Export of hazardous chemicals
When the consignor or its agent of hazardous chemicals for export declares to customs, the following materials must be provided:
- Compliance Declaration of Export Dangerous Chemicals Production Enterprises
- Inspection Result Sheet for the Packaging Performance of Export Goods (excluding bulk products and international regulations exempting the use of hazardous materials packaging)
- Hazardous Characteristics Classification Identification Report
- Dangerous goods label (except for bulk products), sample of safety data sheet. If it is a foreign language sample, a corresponding Chinese translation should be provided.
- For products that require the addition of inhibitors or stabilizers, the actual names and quantities of the inhibitors or stabilizers added should be provided.
Export Dangerous Goods Packaging Inspection
According to the "People's Republic of China Import and Export Commodity Inspection Law," enterprises producing packaging containers for the export of dangerous goods must apply to inspection and quarantine institutions for performance identification of the packaging containers. Enterprises producing dangerous goods for export must apply to inspection and quarantine institutions for usage identification of the packaging containers. Dangerous goods packed in packaging containers that have not passed the identification are not allowed to be exported. The packaging of exported dangerous chemicals should implement performance inspection and usage identification according to the regulations and standards for the inspection and management of packaging for the export of dangerous goods by sea, air, road, and rail.
1) Apply for performance appraisal
Before a production enterprise of export dangerous goods packaging applies for performance verification, it should first apply to the local customs for an export dangerous goods packaging production enterprise code. The enterprise should have the capability to produce packaging products that meet the requirements of international dangerous goods transportation regulations and establish a corresponding quality management system. The enterprise submits a written application to customs, and customs issues the export dangerous goods packaging production enterprise code according to regulations. When applying to customs for performance verification, the following materials need to be submitted:
- Compliance Declaration of Export Dangerous Goods Packaging Container Production Enterprises or Factory Inspection Qualification Certificate of Production Enterprises
- Export Dangerous Goods Packaging Sales Contract
- Packaging Container Periodic Inspection Report
After the performance evaluation is qualified, the customs issues the "Entry and Exit Goods Packaging Performance Inspection Result Sheet."
2) Application for Use Identification
When a manufacturing enterprise exporting dangerous goods applies to the customs for the use of identification, the following materials must be submitted:
- "Declaration of Conformity for Exporting Dangerous Goods" (A "Declaration of Conformity for Exporting Dangerous Chemicals" should be provided when exporting dangerous chemicals) or the manufacturer's factory inspection qualification record.
- Inspection Result Sheet for the Packaging Performance of Export Goods (excluding bulk products and international regulations exempting the use of hazardous goods packaging)
- Hazardous Characteristics Classification Identification Report (Hazardous Characteristics Evaluation Report)
- Export Dangerous Goods Sales Contract
The customs conducts on-site inspections of the packaging of exported dangerous goods on a batch-by-batch basis. After passing the inspection, a "Certificate of Inspection Results for the Use of Packaging for Export Dangerous Goods" is issued.
Hazardous chemicals import and export, compliance and professional logistics are key
The import and export trade of hazardous chemicals promotes industry development while also carrying high risks. From conceptual distinctions to regulatory requirements, and then to logistics transportation guarantees, every link cannot afford to fail. For enterprises to ensure the smooth customs clearance of hazardous chemicals, they must have a deep understanding of laws and regulations, strictly prepare relevant materials as required, and choose professional logistics partners.
Zhongnan Whale Navigation International, with its rich experience, global network, professional team, and compliant operations, is able to provide reliable logistics support for hazardous chemical import and export enterprises, helping companies achieve efficient international trade while ensuring safety. When conducting hazardous chemical import and export business, enterprises must prioritize safety and compliance, working hand in hand with professional logistics to build a solid bridge for hazardous chemical trade.
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