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Background
The revised “Regulations on the Control over the Safety of Hazardous Chemicals”, also known as Decree 591, came into force since 1 Dec 2011. As a key piece of legislation on management of hazardous chemicals in China, it prescribed that the Chinese entry-exit inspection and quarantine authorities (CIQ) at different administrative levels are responsible for the inspection-related duties for the entry-exit hazardous chemicals and their packages.
On 29 Dec 2011, China's General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) and General Administration of Customs (GAC) jointly issued the “Adjustment of 2012 Catalogue of Entry-Exit Commodities Inspected and Quarantined by the Competent Entry-Exit Inspection and Quarantine Authorities” (hereinafter referred to as “the Legal Inspection Catalog”), also known as AQSIQ Notice 1466-2011. One of the biggest changes is that 160 hazardous chemicals listed in the Catalog of Hazardous Chemicals (2002 version) have been added to the Legal Inspection Catalog. Any import/export of the 160 hazardous chemicals will receive compulsory inspections by CIQ as of 1 Feb 2012. However, according to AQSIQ Order No. 30 published on 29 Feb 2012, the inspection scope is expanded to cover all the hazardous chemicals listed in the Catalogue of Hazardous Chemicals.
The AQSIQ Order 30-2012 took effect immediately after being published by the AQSIQ. Therefore, the imported and exported hazardous chemicals that have been listed in the Catalogue of Hazardous Chemicals (2002) are subject to the inspection and quarantine by the CIQ authorities of China since 29 Feb 2012. It is noteworthy that the revised Catalogue of Hazardous Chemicals, which will contain more than 7000 hazardous chemicals, is expected to be released next year.
I. Documents Required for Inspection and Quarantine
Importers | Exporters |
1. Declaration of Conformity for Hazardous Chemicals Importers (officially standard format); | 1. Declaration of Conformity for Hazardous Chemicals Exporters (officially standard format); |
2. Information on the name, quantity (and other conditions) of the inhibitors and stabilizers contained in the imported products, if available; | 2. Information on the name, quantity (and other conditions) of the inhibitors and stabilizers contained in the imported products, if available; |
3. Chinese SDS and label (required to be line with the requirements of relevant Chinese national standards); | 3. SDS and label (The Chinese translations should be provided if the SDSs and labels are non-Chinese ); |
4. Inspection materials such as contracts, invoices, bills of loading /packing list, etc. | 4. Inspection materials such as contracts, invoices, bills of loading /packing list, etc. |
- | 5. Final Packing Performance Inspection List for Exit Goods Transportation” (bulk products are exempted); |
- | 6. The Hazard Identification and Classification Report of Chemicals. |
II. The Inspection Items of Imported and Exported Hazardous Chemicals
The inspection items of imported and exported hazardous chemicals include compliance requirements regarding safety, hygiene, health, environmental protection and prevention of fraud as well as items on the related product quality, quantity and weight, etc. Specifically, inspection items on safety include the following requirements:
Whether information on the main compositions/constituents of the product, its physical- chemical properties and hazard category is compliant with the relevant standards;
Whether a precautionary label has been affixed on the packaging (For imported products, a China GHS-based label should be provided) and whether a Safety Data Sheet has been provided along with the goods; whether the contents of the label and SDS are compliant with the relevant national standards.
III. Inspection on the Packages of the Imported and Exported Hazardous Chemicals
For packages of imported hazardous chemicals: Identify whether the models, category, specification, unit quantity and mark of packaging meet the requirements of relevant standards.
For packages of exported hazardous chemicals: Conduct the performance and use test on the packages in accordance with the measures on the management of packaging inspection of dangerous goods exported by air, sea, road and railway. The “Performance test result of transport packages for exit goods” and “Use test result of transport package for exit dangerous goods” need to be displayed by the packaging manufactuers and hazardous chemicals exporters respectively.
Supervision Information from CIQs and Our Advices
The inspection of imported hazardous chemicals mainly focuses on whether the contents and formats of the labels and SDSs for hazardous chemicals conform to the relevant national standards. Recently several bathces of chemicals have been held or be detained by the entry port due to the unqualified SDSs or labels. Statistics from the CIQs shows that reasons for the unqualified labels or SDSs are mainly concentrated on the language problem (such as hazardous chemicals were labelled only in English other than Chinese); unqualified emergency telephone numbers; and non-compliance in formats and contents with Chinese national standards, etc.
It is strongly recommended that companies shall prepare Chinese SDSs and labels in compliance with Chinese GHS national standards beforehand for all hazardous chemicals to avoid any delay in customs clearance and possible fines.
