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China MOT Consults on New Regulation for Road Transport of Dangerous Goods

On Mar 28, China Ministry of Transport issued the newly drafted Measures for the Safety Administration of Road Transport of Dangerous Goods, which will be promulgated by a joint order of 6 departments when finalized, including Ministry of Transport (MOT), Ministry of Public Security (MPS), State Administration of Work Safety (SAWS), Ministry of Industry and Information Technology (MIIT), General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) and Ministry of Environmental Protection (MEP). The consultation period is scheduled to end on Apr 15.

The new regulation consists of 71 articles and 11 chapters stipulating the general principles, consignment, cargo carriage, limited quantities and excepted quantities, loading and unloading, DG vehicles & portable tanks & tank containers, transport routes, emergency response, supervision and multi-department collaboration, legal liabilities and supplementary provisions.

Similar to the existing Provisions on the Administration of Road Transport of Dangerous Goods (MOT Order No.2 of 2013), “dangerous goods” in the draft Measures refer to substances, materials and articles included in the List of Dangerous Goods (GB 12268). The difference is that in the draft Measures civil explosives, fireworks, radioactive articles and hazardous wastes are also included in the regulatory scope.

The draft Measures details the necessary shipping documents for different types of dangerous goods:

Dangerous Goods (DG)


(should provide the carrier with:)


(should prepare and/or take along:)

All types of DG

Inventory for TDG consignment, including information on the consignor, receiver, loading company, place of departure, destination, shipping company, UN number, product name, DG class and division, packing group and specification, quantity, and 24/7 emergency telephone number, with appendix specifying the safety information including hazards of the product, shipping notes, first-aid measures, firefighting measures, accidental release measures, etc.

● DG shipping paper, including information on the consignor, receiver, loading company, place of departure, transport route, shipping company, vehicle, tank container, date of departure, driver, cargo escort, UN number, product name, DG class and division, packing group and specification, quantity, 24/7 emergency telephone number provided by the consignor, shipping notes, etc.

● Safety card for road TDG

DG with unknown hazards

Identification report issued by accredited institutions


Civil explosives (Decree 455) and fireworks (Decree 653)

Road transport permit issued by public security administrations

Road transport permit provided by the consignor

Highly toxic chemicals (Decree 591)

Road transport approval issued by public security administrations


Road transport approval provided by the consignor

Type I radioactive articles (Decree 562)

Ratification of Nuclear and Radiation Safety Report for Transport of Radioactive Articles issued by National Nuclear Safety Administration (NNSA) under MEP

NNSA’s rectification provided by the consignor

Hazardous wastes (President Order 31 in 2004)

Manifest Forms for Transferring Hazardous Wastes issued by environmental protection administrations

Manifest forms provided by the consignor (after filling in the required blanks)

To ensure traceability, the shipping documents should be kept for at least 1 year. In addition, loading companies should keep the loading inventory for at least 1 year. The Measures also reiterates the requirement of establishing a national information system to share Hazchem/DG information throughout the supply chain and among the different supervisory departments.

It's worth mentioning that the draft Measures is China’s first ever regulation specifying the exemptions for transporting dangerous goods packed in small quantities, i.e. limited quantities (LQ) and excepted quantities (EQ). Two related compulsory standards GB 28644.1 & GB 28644.2 were developed and entered into force in 2012, but their implementation has been severely impeded as none of the existing laws or administrative regulations introduces the concept of LQ & EQ and makes reference to the standards directly. The new Measures are believed to be a breakthrough though under which exemptions can only be obtained by:

  • Hazchem manufacturers who have acquired safe production license from Administrations of Work Safety

  • Academic, researching, military, etc. institutions

In addition to that dangerous goods should be appropriately offered as LQ/EQ in accordance with the mentioned national standards, an eligible consignor has to provide the carrier with either the packaging performance test report or written statement of compliance with the packing and packaging standards, while the carrier is obliged to guarantee sufficient training of their employers and archive and retrieve the training records in case of inspections.


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