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FAQ on Import and Export of Hazardous Chemicals and Packaging Inspection

The General Administration of Customs Announcement No. 129 of 2020 "Announcement on Issues Concerning Import and Export of Hazardous Chemicals and Packaging Inspection and Supervision" has been implemented. The customs has successively received business consultations from many import and export companies, Specially select 9 representative questions among them. For specific questions, we will prepare answers to frequently asked questions about the inspection and supervision of import and export hazardous chemicals and their packaging for the reference of relevant companies.

1.Should inspections be carried out on hazardous chemicals imported through processing trade?

A:Hazardous chemicals involve safety issues. Therefore, in principle, hazardous chemicals imported by various trade methods need to be inspected, and hazardous chemicals imported by processing trade also need to be inspected in accordance with the import and export hazardous chemical inspection requirements.

2.The safety data sheet of the mixed liquid shows that the flash point is "not applicable". Can it be judged that it does not belong to the chemicals listed in the list of dangerous chemicals (2015 Edition)?

A:The mixture is first searched with its main components in reference to the pure substance to see if there is a corresponding XXX mixture entry (such as 124 "propyne and propadiene mixture [stable]", 276 "polybrominated diphenyl ether mixture", etc.), If there is a corresponding item, it is judged to belong to the item;

If there is no corresponding item, it mainly depends on whether the flash point is less than or equal to 60℃, and the conformity is judged to belong to Article 2828 of the "Dangerous Chemical Catalog (2015 Edition)"

The general judgment that does not meet the above-mentioned conditions is that it does not belong to the chemicals listed in the "Hazardous Chemicals Catalog (2015 Edition)".

4.Is it necessary for the export of chemicals to require enterprises to provide classification and identification reports of hazardous characteristics?

A:According to the “Announcement of the General Administration of Customs on Issues Concerning the Inspection and Supervision of Import and Export of Hazardous Chemicals and Their Packaging” (Announcement No. 129 in 2020), the classification and identification report of hazardous characteristics is an essential material for the declaration of hazardous chemicals for export, such as determining the goods Enterprises should provide the chemicals listed in the "Dangerous Chemicals Catalog (2015 Edition)".

5.There is only the letter "UN" on the package. Does it meet the requirements without a circle?

A:The UN packaging symbol is used to prove that the packaging container complies with the requirements of the UN "Recommendations on the Transport of Dangerous Goods, Model Regulations". The conventional packaging symbol is the lowercase "u" and "n" arranged up and down in a circle, but for metal packaging, it can be directly replaced by molded capital letters "UN". In railway and road transportation, the symbols "RID" and "ADR" can also be used instead.

6.Is it necessary to provide a classification and identification report of hazardous characteristics for imported hazardous chemicals?

A:The customs does not collect the classification and identification report of hazardous characteristics for imported hazardous chemicals

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7.Can the labeling of small packages of hazardous chemicals be simplified?

A:According to the "Provisions for the Preparation of Chemical Safety Labels" (GB 15258-2009), for small chemical packages of less than or equal to 100mL, for the convenience of labeling, the elements of the safety label can be simplified, including chemical identification, pictograms, and signal words , Hazard statement, emergency consultation telephone, supplier name and contact telephone number, and information can be referred to the prompt language.

8.Does a dangerous goods business enterprise need to apply to the customs for appraisal of the use of dangerous goods packaging?

A:According to the "Import and Export Commodity Inspection Law of the People's Republic of China" and its implementation regulations, enterprises that produce dangerous goods must apply to the commodity inspection agency for appraisal of the use of packaging containers. The appraisal of the use of dangerous goods packaging shall be handled by the dangerous goods production enterprise to the local customs.

9.What is the scope of inspection of import and export hazardous chemicals?

A:According to the "Regulations on the Safety Management of Hazardous Chemicals" (Order No. 591 of the State Council) and the "Announcement of the General Administration of Customs on Issues Concerning the Inspection and Supervision of Import and Export of Hazardous Chemicals and Their Packaging" (Announcement No. 129 of 2020), the current customs Carry out inspections on the import and export hazardous chemicals listed in the "Dangerous Chemicals Catalog (2015 Edition)".


Post time: 28-07-21

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