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Shanghai Customs to Fully Implement New Inspection Mode for Imported Hazardous Chemicals from February 2023

The frequency of sampling inspection has increased during the pilot period.

The General Administration of Customs of China (GACC) decided to pilot the new inspection mode for imported hazardous chemicals - “100% Manual Review for Verification + Port Inspection or Destination Inspection” in Shanghai for three months starting from December 1, 2022 (CL news). During the past two-month pilot period, enterprises encountered many problems in this regard. To help enterprises ensure their compliance, Shanghai Customs held a virtual forum on January 30, 2023. Below is the schedule of this pilot project, shared by the official.

  • From December 1, 2022

    Shanghai Pujiang Custom has implemented the new inspection mode for imported hazardous chemicals.

  • From January 1, 2023

    The application of the new inspection mode has been expanded from ports to airports. That is to say, the imported hazardous chemicals declared to the airport customs in Shanghai shall be inspected in this new mode as well.

  • From February 1, 2023

    The new inspection mode will be carried out by all the customs (codes of relevant customs districts: 2201 ~ 2249) under the jurisdiction of Shanghai Customs.

According to the official, the frequency of sampling inspection for imported hazardous chemicals increased significantly during the past pilot period. However, as an action taken to gain better grasp of the situation, such increase is considered temporary and unlikely to be maintained after the nationwide deployment of the new inspection mode in the future.

The official also shared attendees the answers to the FAQs solicited from stakeholders. ChemLinked selected 4 FAQs to address some problems in filling in the Declaration of Conformity and sampling inspection.

1. For a mixture containing many ingredients that are substances listed in the Inventory of Hazardous Chemicals, how to fill out the Declaration of Conformity?

Chemical names of all the ingredients should be stated in the Declaration of Conformity. However, if there are too many ingredients in the mixture, you can fill in chemical names of 2 ~ 3 ingredients with the highest concentration.

2. If the non-hazardous chemicals and hazardous chemicals have been declared together in one import declaration, is it mandatory to submit the declaration of conformity for the non-hazardous chemicals?

No. There’s no need to submit Declaration of Conformity for non-hazardous chemicals. Non-hazardous chemicals can be declared via the single window as non-hazardous chemicals.

3. Is the same product with different specifications exempted from sampling inspection?

No.

4. Can high-value hazardous chemicals be exempted from sampling inspection? Is there a whitelist for hazardous substances imported at low volume for R&D purposes?

High-value hazardous chemicals that have been tested by customs laboratories can be exempted from sampling inspection within one year. Imported hazardous chemicals with a total net weight < 100g are exempted from sampling inspection. It is expected to relax the quantity limits for exemption from sampling inspection.

As for the whitelist, it is under consideration. 

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