FAQs about “Green Channel” for 100% Ingredients Disclosure Issues on DG Cargoes Shipped via Shanghai Waigaoqiao Port as per the Yangtze River Protection Law

In February and May of 2022, the Shanghai Maritime Safety Administration (MSA) respectively released two notices to address issues on the 100% ingredients disclosure of dangerous goods (DG) that shipped via the Waigaoqiao Area of Shanghai Port. ChemLinked has reported on it and offered analysis articles:

Dangerous Goods Shipping in Yangtze River Basin: How to Deal with the Recent Ingredients Disclosure Requirements by Maritime Safety Administration (regarding the Shanghai MSA’s notice issued in February)
Shanghai MSA Clarifies Must-Know Issues for Shipping Dangerous Goods via Waigaoqiao Area of Shanghai Port: 100% Ingredients Disclosure is Not Mandatory (regarding the Shanghai MSA’s notice issued in May)

The second notice issued in May introduced a new method (called “Green Channel - Pre-review and Publicity Service”) for shippers to prove their DG cargoes are allowed to transport in the Yangtze River Basin, while without revising the original SDS and disclosing 100% ingredients. However, there are still many questions raised by enterprises in actual application for pre-review and public announcement of their DG cargoes. ChemLinked collected some frequently asked questions and inquired the officials from the Shanghai MSA. Below are the FAQs for your reference.

1. If the SDS indicates that none of the three indicators (Acute Toxicity, Acute Aquatic Toxicity, Chronic Aquatic Toxicity) falls into Category 1, can shippers apply for the pre-review and public announcement of their DG cargoes?

2. Can overseas enterprises apply for the pre-review and publicity service? Or only the domestic enterprises in China can apply for it?

Overseas enterprises can apply to the Shanghai MSA for such service as well.

3. If overseas enterprises can apply for the pre-review and publicity service, will the authority make public the information of overseas enterprises?

Yes. Enterprises can determine what kind of information to be made public.

4. Will the shipping companies transport the goods after the authority makes public the name of non-embargoed goods and the shippers on the official website? Except for online public announcement, will the authority provide enterprises any other evidentiary materials?

The Shanghai MSA only makes public online the results of the pre-reviews. There’re no other evidentiary materials will be provided to the enterprises. The online public announcement will disclose information of consignee/shipper, the goods' Chinese name, specifications, UN number, and hazard classification (see screenshot below).

5. In addition to the SDS with 100% ingredients information (including chemical name, CAS number, hazard classification, concentration, etc.), are there any other materials required by the authority for the application for pre-review and publicity service?

An official from the Shanghai MSA shared that the following materials are required:

Written application which states basic information, e.g., what are the goods, the origin and destination (shipping route), reason for applying for the service, etc.; and
SDS of all the goods that are to be transported.

The Shanghai MSA may require more information if necessary.