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On July 8, 2024, the General Administration of Customs of China (GACC) announced to pilot of an inspection reform for the export of hazardous chemicals and their packaging nationwide. This inspection reform is carried out in the mode of “One-time on-site inspection, multiple declarations”. It has been piloted in certain cities like Ningbo, Shanghai, etc. since October 2023 and has achieved significant success. Therefore, the GACC decided to roll out it nationwide now. The inspection reform will bring some changes to the declaration and customs clearance for companies exporting hazardous chemicals. Highlights are summarized below.
Inspection mode – “One-time on-site inspection, multiple declarations”
Before this reform, the Customs carry out 100% on-site inspections for every batch of exported hazardous chemicals and dangerous goods packaging. According to the GACC Notice, qualified companies are designated as pilot companies* to undergo the inspection in the mode of “One-time on-site inspection, multiple declarations”. For the “same batch” (interpreted afterward) of exported hazardous chemicals or dangerous goods, the Customs will conduct on-site inspections and sampling only during the first declaration by a pilot company. If the initial on-site inspection is qualified, within the “inspection cycle” (interpreted afterward), the Customs can verify subsequent declarations of the “same batch” by reviewing relevant declaration documents without further on-site inspections.
*Pilot companies refer to companies that are certified by the Customs as Authorized Economic Operator (AEO), and trustworthy companies that have passed risk evaluations conducted by customs. Priority is given to AEOs.
Inspection scope
This inspection reform applies to the exported hazardous chemicals in China's Inventory of Hazardous Substances (latest version), as well as the exported dangerous goods that are included in the Dangerous Goods List of the UN Recommendation on the Transport of Dangerous Goods Model Regulations (excluding Division 6.2 Infectious Substances and Class 7 Radioactive Material) and their packaging, which are declared to the Customs by the pilot companies.
Definition of “same batch”
For inspection on hazardous chemicals:
The exported hazardous chemicals produced by the same manufacturer, using the same process, with consistent components and hazards are considered the same batch.
For inspection on compliance use of dangerous goods packaging:
Exported dangerous goods of the same type, components, and content, packaged by the same manufacturer using the same transportation mode and specifications, are considered the same batch. For paints with only color differences but consistent hazards, they can be treated as one physical batch.
For inspection on performance of dangerous goods packaging:
Packages of exported dangerous goods that produced by the same manufacturer, with the same design, material, and process, are considered the same batch.
Inspection cycle
According to the implementation guideline annexed to the GACC Notice, local customs authorities can determine the inspection cycle based on the local supervision situation. That’s to say, for different customs districts, the inspection cycle may be different.
Notably, according to the previous pilot implementation in Ningbo, Shanghai, etc., the inspection cycles for different inspection items are as below:
For inspection on hazardous chemicals: One year for the same batch of exported hazardous chemicals.
For inspection on the compliance use of dangerous goods packaging: Until the qualified packages (passing the initial on-site inspection) are used up for the same batch of exported dangerous goods.
For inspection on the performance of dangerous goods packaging: One year for the same batch of exported dangerous goods.
The key benefit of this inspection reform is to improve customs regulatory efficiency, reduce companies’ compliance costs, and facilitate trade through the inspection mode of "one-time on-site inspection, multiple declarations". However, companies must also strictly fulfill their obligations, ensure complete documentation, and fully cooperate with customs to ensure smooth customs clearance. It should be noted that:
The implementation details, such as the scope of pilot companies and inspection cycles, may vary across different customs districts.
Within the inspection cycle, the Customs will still conduct spot checks on the hazardous chemicals exported by pilot companies.
Pilot companies must ensure production and transportation safety, product quality, and maintain good credit standing.
