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Updates:
Shanghai Customs recently issued a notice, announcing that the pilot period of inspection mode reform has been extended to the end of March 2023.
This pilot project was previously scheduled to last for 3 months starting from December 1, 2022. Below is the schedule shared by the official on a virtual forum held on January 30, 2023.
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On the virtual forum, the official also shared attendees the answers to the FAQs solicited from stakeholders, see here.
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On November 25, 2022, Shanghai Customs issued a notice to announce the pilot reform of the inspection mode of imported hazardous chemicals.
Background
The General Administration of Customs of China (GACC) implemented the Announcement on Questions Regarding the Inspection on Imported and Exported Hazardous Chemicals and Their Packaging (a.k.a. GACC Announcement No. 129 of 2020) from January 10 of 2021, which is considered as the guiding document for customs agencies to fulfill their duties concerning the inspection on imported and exported hazardous chemicals and their packaging. However, there are still some problems undressed in practice, e.g., all the imported hazardous chemicals gathering at the port of discharge may be risky and the different requirements for inspection at different customs port may lead to low efficiency of customs clearance. To standardize the operational requirements for the inspection and prevent false declaration and concealment, the GACC decided to reform inspections and pilot in Shanghai Port, as it’s China’s largest seaport for the import and export of hazardous chemicals.
Pilot Period
The pilot reform project will last for 3 months starting from December 1, 2022.
Application Scope and Implementation Steps
The pilot reform project will be implemented for hazardous chemicals declared to Shanghai Pujiang Customs for import, and it will be gradually extended to all hazardous chemicals imported from ports under the jurisdiction of Shanghai Customs. The pilot experience will be used for reference by other provinces and cities, finally, it will be rolled out nationwide.
Pilot Inspection Mode
The pilot reform of inspection will be carried out at Shanghai Pujiang Customs in the mode of “100% Manual Review for Verification + Port Inspection or Destination Inspection”. The customs will designate the place and proportion to perform inspection of the imported hazardous chemicals according to their properties and packaging types.
ChemLinked Insights
Main points of the new inspection mode are summarized as below.
Inspection scope
It applies to hazardous chemicals listed in the Inventory of Hazardous Chemicals* and their packaging. It is recommended to carry out the hazard identification of hazardous chemicals if they are with uncertain hazardous properties.
| *The Inventory contains 2,828 well-recognized hazardous chemicals, of which the Entry No. 2828 representing a large group of chemicals with closed cup flash point not exceeding 60℃ (e.g., synthetic resin containing flammable solvents, paints, auxiliary materials, coatings, etc.). |
100% manual review for verification
For the imported hazardous chemicals, Shanghai Pujiang Customs will review manually to check if the information** filled in via the online system (https://www.singlewindow.sh.cn/winxportal/) is consistent with their import declaration materials. The manual review rate will be increased from 20% to 100%.
**Information shall be filled in via the online system include: Cargo attribute, project of inspection and quarantine, hazard class, UN number, packaging group, UN markings, inspection and quarantine department at the destination, etc. Import declaration materials include:
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Place to perform inspection (the port of discharge or the destination)
The Regulations on Enforcement of Import and Export Commodity Inspection Law, stipulates that the import commodities subject to statutory inspection shall be inspected by the customs at port. For the imported hazardous chemicals, the inspection can be performed at the port of discharge or destination upon the need of convenience for foreign trade and commodity inspection. Consignees and consignors or their agents whose domestic destinations of imported hazardous chemicals are outside Shanghai are requested to truthfully report to the inspection and quarantine authority of the destination. After customs declaration, they must promptly check the inspection notice (see figures below) through the "single window" to confirm the inspection customs and inspection location.
The customs will inspect the followings:
a) Whether or not the package is intact.
b) Whether or not the information displayed on the affixed label consists with that contained in the import declaration materials.
c) Whether or not the label and SDS are prepared in line with Chinese standards.
d) Whether or not the marking of transport packages and the warning signs for dangerous goods meet the requirements, and whether they consist with the import declaration materials.
e) Whether or not the hazard properties (including appearance, state and other physical and chemical properties) of the products in the package consist with the declared products.
Note: Bulk hazardous chemicals are not subject to the inspection on dangerous goods packaging and label.
As per the notice, for imported hazardous chemicals that are required to be inspected at the port of discharge, the customs will confirm whether the custom port has the conditions for inspection based on the properties of hazardous chemicals, their packaging and the actual safety situation at the port. If not, the hazardous chemicals shall be transferred to the destination for inspection in time. ChemLinked has obtained first-hand information that hazardous chemicals transported in excepted quantities, hazardous chemicals that are not considered as dangerous goods, etc. will probably be subject to inspection at the destination.
