Over the past couple of weeks, we have heard of instances where Chinese Customs are asking for package codes on packages such as Excepted or Limited Quantity that do not require them and for SDS that are likewise not required for some products/articles.

The source appears to be the following Customs requirement. We suggest that Members bring this to the attention of their customers shipping to China as it could well cause problems in clearance.

Representatives of Dangerous Goods shippers have contacted the Department for Transport for guidance and clarification. As an interim measure it is being suggested that shippers may have to use UN-certified boxes.

The document has been translated from Chinese and we believe that it will provide some clarity.
 

Announcement of the General Administration of Customs of China

Issue Date：2021-04-14 

In accordance with the Regulation on the Safety Management of Hazardous Chemicals (Order No. 591, State Council), the Customs are responsible for conducting the inspection of imported and exported hazardous chemicals and the packaging thereof. The relevant issues are hereby announced as follows:

I. The Customs shall conduct the inspection of the imported and exported hazardous chemicals that are listed in the national “Catalogue of Hazardous Chemicals” (the latest version).

II. When the consignee of imported hazardous chemicals or the agent makes a declaration to the Customs, the matters to be filled out shall include the hazard category, category of packaging (except for bulk cargo), United Nations Dangerous Goods Number (UN Number), UN Marking for the Packaging of Dangerous Goods (UN Markings for Packaging) (exceptfor products in bulk), etc., and the following materials shall also be provided:

1. Declaration of Conformity of Enterprises Importing Hazardous Chemicals (see Annex 1 for the format);

2. the names, quantities and other information of the actual added inhibitor or stabilizer, for products that need to add any inhibitor or stabilizer; and

3. Danger notice labels in Chinese (except bulk cargo, similarly hereinafter) and sample of Chinese safety data sheets.

III. The consignor of exported hazardous chemicals or the agent, when making a declaration for inspection to the Customs], shall provide the following materials:

1. Declaration of Conformity of Production Enterprises Exporting Hazardous Chemicals (see Annex 2 for the format);

2. Inspection Results of Performance Packaging for Transportation of Exported Goods (except for products in bulk);

3. a report on identification of hazard characteristics by categories;

4. danger labels (except for products in bulk, similarly hereinafter) and sample of safety data sheets, for which the corresponding Chinese translations shall be provided if they are in foreign language; and

5. the names, quantity and other information of the actual added inhibitor or stabilizer, for products that need to add any inhibitor or stabilizer.

IV. Importers and exporters of hazardous chemicals shall ensure that imported and exported hazardous chemicals satisfy the following requirements:

1. compulsory requirements of the national technical specifications of China (applicable to imported products);

2. relevant international conventions, international rules, treaties, agreements, protocols, memorandums, etc.;

3. technical regulations and standards of importing countries or regions (applicable to exported products); and

4. technical regulations and standards designated by the GACC and the former General Administration of Quality Supervision, Inspection and Quarantine.

V. The inspection of imported and exported hazardous chemicals shall include:

1. whether the main composition/ component information, physical and chemical properties, hazard category, etc. of the products comply with the provisions of Article IV of this Announcement; and

2. whether the product packaging has the hazard label (the Chinese danger label is required for imported products), whether the safety data sheet is attached (Chinese version is required for imported products), and whether danger label, safety data sheet content is consistent with the provisions of Article IV of this Announcement.

VI. For the packaging used for inbound hazardous chemicals, it shall be checked whether the packaging type, packaging mark, packaging category, packaging specification, unit weight, packaging usage status, etc. comply with the provisions of Article IV of this Announcement.

VII. For the packaging of imported hazardous chemicals,, and the "Inspection Results of Performance of Exported Goods Transport Package" and “Identification Result Sheet for Use of Exported Dangerous Goods Transport Packaging” shall be issued respectively in accordance with the regulations and standards for the inspection and management of exported dangerous goods packaging by sea, air, road and railway transportation.

VIII. Imported and exported hazardous chemicals used as food and food additives shall comply with relevant food safety regulations.

IX. This Announcement will come into effect on January 10, 2021, and the former AQSIQ Announcement No. 30 of 2012 shall be repealed at the same time.