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Case Analysis Regarding China’s New Inspection Mode of Imported Hazardous Chemicals

The General Administration of Customs of China (GACC) announced to impose “Document Review + Port Inspection or Destination Inspection” on each batch of imported hazardous chemicals nationwide from 13 April 2023 (CL news). Local customs authorities are actively enforcing it to strengthen the supervision of hazardous chemicals. So far, more than a month has passed since the fully implantation of this new inspection mode. The reform of the inspection mode has reduced both the storage quantity and duration of hazardous chemicals in ports, effectively mitigating the accumulative risk at ports and improving customs clearance and port operation efficiency. Many enterprises shared with ChemLinked that, under the new inspection mode, customs clearance takes 2 to 5 days shorter than before.

Below are some cases regarding this new inspection mode disclosed by some local customs authorities.

Case 1 - Performing destination inspection for 36 tons of imported chromium trioxide

Publication Date: 2023.5.15

Customs Authority: Huangdao Customs under the jurisdiction of Shandong Customs

Details: According to the new inspection mode, customs authorities will determine the operation locations to carry out inspections according to the properties and packaging types of the imported hazardous chemicals. Imported hazardous chemicals of low risk may probably be subject to destination inspection. Mr. Zhen Jun, an official of Huangdao Customs, introduced that the imported chromium trioxide is a listed hazardous chemical in the Inventory of Hazardous Chemicals, and the enterprise has declared it to the customs via the Single Window in advance. The customs reviewed the submitted documents before the cargo arrived at the port and determined that this cargo is of low risk and can be inspected at the destination declared. Therefore, when this cargo arrived at Qingdao Port, the customs authority at the port directly released the cargo and immediately sent the notice of inspection location, performing destination inspection (in Jinan, Shandong) rather than port inspection.

Case 2 - Concealing declaration of flammable liquid (1.28 tons of isopropanol)

Publication Date: 2023.5.10

Customs Authority: Wusong Customs under the jurisdiction of Shanghai Customs

Details: Wusong Customs recently inspected a cargo of imported metal surface pickling agent. The customs found that the components of this agent contain 59% isopropanol (2-Propanol) in a quantity of 1.28 tons, which is considered as flammable liquid. After testing, the customs confirmed that this component is a listed hazardous chemical in the Inventory of Hazardous Chemicals and should be declared as ‘hazardous chemicals. However, the inspected cargo has not been declared as required, due to the concealment, it has been handed over for follow-up disposal according to law.

Similar concealments were also disclosed by other customs authorities, e.g., Huanggang Customs in Shenzhen, Yangshan Customs in Shanghai, Tianjin Customs, etc. Declaration concealments of hazardous chemicals are the most violations detected by local customs authorities. Although the new inspection mode has effectively improved customs clearance efficiency and reduced warehousing costs, local customs authorities do not relax the supervision of imported hazardous chemicals.

To help enterprises gain a more accurate and comprehensive understanding of the latest compliance requirements for the new inspection mode of imported hazardous substances in China, ChemLinked plans to stage a free webinar on 15 June 2023. The webinar is now open for registration. Please click here to save your seat.

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