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On December 21, 2020, the General Administration of Customs of China (GAC) issued the Announcement on Questions Regarding the Inspection on Imported and Exported Hazardous Chemicals and Their Packaging (GACC Announcement No. 129 of 2020)[1](Hereinafter referred to as the Announcement), which took effect on January 10, 2021 (ChemLinked news)[2]. Given many problems encountered by stakeholders during the implementation in practice, Shenzhen customs[3] published fifteen frequently asked questions.
Hazardous chemicals involve safety issues. In principle, hazardous chemicals imported through various trade methods must be inspected. Therefore, those imported in the form of processing trade must also be inspected following the inspection requirements for the import and export of hazardous chemicals.
Ammonia is a hazardous chemical listed in the Catalog of Hazardous Chemicals (2015)[4](Hereinafter referred to as the Catalog) and should be inspected by the customs.
First, search the mixture with its main components with reference to the pure substance to see if there is a corresponding XXX mixture entry (e.g. Entry No.124 "propargyl and propadiene mixture [stable]", Entry No.276 "polybrominated diphenyl ether mixture", etc.). If so, it belongs to the entry.
If there is no corresponding entry, it mainly depends on whether the flash point is ≤60℃, and if it is, it belongs to Entry No. 2828 of the Catalog.
Those that do not conform to the above circumstances generally don’t belong to the chemicals listed in the Catalog.
According to the Announcement, the identification report for the classification of hazardous characteristics is necessary for the declaration of exported hazardous chemicals listed in the Catalog.
According to the experience of classification, ethanol disinfection wipes do not belong to the chemicals listed in the Catalog and are not subject to inspections of imported and exported hazardous chemicals. However, it may belong to dangerous goods. The specific UN number and category of dangerous goods shall be identified through the identification of classification of hazardous characteristics.
According to the Law of the People's Republic of China on Import and Export Commodity Inspection[5]and its implementing provisions, and the Provisions on the Declaration for Exit-Entry Inspection and Quarantine (General Administration of Customs Order No. 243 - 21)[6], enterprises producing packaging containers for dangerous goods for export must apply to the customs for performance inspection of packaging containers, and enterprises producing dangerous goods for export must apply to the customs for appraisal of the use of dangerous goods packaging containers.
The UN packaging symbol is used to prove that the packaging container complies with the provisions of the UN Recommendations on the Transport of Dangerous Goods- Model Regulations[7](Hereinafter referred to as the Model Regulations). The conventional packaging symbol is a circle with a lowercase "u" and "n" arranged above and below, which can be replaced by the molded capital letter "UN" in metal packaging. For rail and road transport, the symbols "RID" and "ADR" can also be used instead.
Generally, lithium batteries shall implement the use appraisal of dangerous goods packaging for export. However, those that meet the special provisions of Article 188 of the International Maritime Dangerous Goods Code[8] can be exempted, and the specific rules for the transportation of dangerous goods shall prevail.
Different requirements for specific goods can be applied with reference to the specific provisions of Model Regulations. For example, the lead-acid battery UN2800, which has been tested to meet the special provisions of Article 238, does not need to follow the provisions of the Model Regulations and can be transported as ordinary cargo. The Model Regulations have no specific requirements on whether to label the UN mark. Lithium-ion batteries UN3090, UN3091, UN3480 and UN3481 tested in accordance with special provisions of Article 188 are not subject to the other provisions of the Model Regulations, but shall be labeled with lithium battery mark.
It is not required for the customs.
According to the GB 15258-2009 General Rules for Preparation of precautionary label for chemicals[9], the safety labeling elements of small packages of chemicals less than or equal to 100mL can be simplified for convenience, as long as chemical identification, pictogram, signal word, hazard statement, emergency consultation telephone number, supplier name and contact number, and information reference prompt are included.
According to the provisions of the Catalogue and the Model Regulations, most ethanol disinfectants are both hazardous chemicals and dangerous goods. If they belong to the dangerous goods listed in the Model Regulations, the enterprise should declare to the customs at the place of origin the use appraisal of packaging containers for the export of dangerous goods, and if they meet the relevant provisions of the limited quantity or the excepted quantity of dangerous goods, they can be exempted from applying for the use appraisal of dangerous goods packaging; if they belong to the hazardous chemicals listed in the Catalogue, enterprises should apply to the customs for export inspection of dangerous chemicals at the place of origin.
The alcohol gel hand sanitizer may involve "synthetic resins, paints, auxiliary materials, coatings and other products containing flammable solvents [closed-cup flash point≤60℃]" in Entry No. 2828 of the Catalog, so it is recommended to identify the classification of hazardous characteristics when exporting. If it belongs to hazardous chemicals, enterprises shall apply to the customs of origin for inspection. If it belongs to the dangerous goods listed in the Model Regulations, the enterprise shall declare to the customs at the place of origin the use appraisal of packaging containers for the export of dangerous goods. If it meets the relevant provisions of the limited quantity or the excepted quantity of dangerous goods, it can be exempted from applying for the appraisal.
According to the Import and Export Commodity Inspection Law of the Republic of China[10] and its implementing provisions, enterprises producing dangerous goods for export must apply to the commodity inspection agency for appraisal of the use of packaging containers. They shall apply to the local subordinate customs for handling the formalities.
