Status and Trend in Inspection of Hazardous Chemicals in China

In March of 2018, China’s State Council outlined its plans for sweeping institutional reforms which would significantly impact administration of China’s various industries in addition to significantly impacting market access and regulatory compliance requirements for industry. In terms of importation and exportation of hazardous chemicals one of the most impactful changes included in this reform package was changes to the administration of customs inspection and the previously separated functions of supervision and quarantine of imported and exported goods. Under the new reforms, the responsibility to conduct quarantine and supervision of all imported/exported goods which was previously designated to the now disbanded AQSIQ (mediated through the activities of subordinate provincial CIQ departments) is now designated to China Customs.

The scope of inspection on hazardous chemicals import and export are as follows:

• listed products in the Catalogue of Import and Export Commodities

• Other laws and regulations stipulated by the inspection and quarantine department. For example, the Regulations on the Safe Management of Hazardous Chemicals regulates that “the inspection and quarantine department is responsible for the inspection of import and export hazardous chemicals and their packages”. The Commodity Inspection Law (article 17) regulates that the packages of dangerous goods for export shall be subject to performance inspection. (Note: packing of imported dangerous goods is excluded)

Currently, in China, there are 190 ports for inspection of import and export of hazardous chemicals, among which 132 are for import and 143 for export. There are 836 types of hazardous chemicals under inspection, including 496 types for import, 534 for export and 194 for both import and export, covering eight of the nine categories of hazardous chemicals (excluding radioactive substances) specified by the United Nations.

Our speaker at CRAC 2018, Xiao Huanxin from Guangxi Entry-exit Inspection and Quarantine Bureau, has given statistics showing data on the supervision of import and export of hazardous chemicals in 2017. A total of 250619 batches of hazardous chemicals were examined by local inspection and quarantine bureaus. However, 17.82% of imported batches failed inspection while 4.32% of exported batches failed. (See table 1)     

Table 1

Regarding hazardous chemicals, the top reason for inspection failure was the use of nonstandard safety signs (see table 2 and table 3). Nonstandard signs include ①lack of hazard label/SDS in Chinese ②nonstandard label or SDS: lack of an emergency call number/wrong pictogram etc. Interestingly, the nonstandard packaging is a major reason for export inspection failure (1181 batches) while only 90 for import failed inspection for the same reason. Unqualified packaging includes  

1. Hazardous chemicals are not packaged as dangerous goods, or package does not meet UN standard.
2. The packaging mark does not meet the requirements of China's mandatory technical specifications; the use of packaging without UN dangerous goods packaging code.
3. The packaging of imported hazardous chemicals is damaged, leaked, deformed and cracked due to improper handling and securing during transportation, handling and/or storage;
4. The packaging code application method does not meet the requirements of the standard regulations;
5. The packaging container is not used according to the grade and limit as shown in the packaging mark.

Table 2

Table 3

China is expected to further strengthen on the management of imported hazardous chemicals through campaigns such as the “Two 100% campaign”. Chemlinked would like to remind our customers to stay abreast of all changes to port inspection policies.