For the import and export supervision of dangerous chemicals and dangerous goods, the basic supervision logic of customs is that the import and export of dangerous chemicals need to report to customs and provide relevant declaration information according to law, and for dangerous chemicals that belong to dangerous goods at the same time, their packaging needs to meet the supervision requirements of customs for dangerous goods. And the customs supervision requirements for dangerous goods are mainly focused on the performance identification and use identification of the packaging of exported dangerous goods, and for imported dangerous goods, mainly for the compliance inspection of the packaging. In order to make the logic clearer, the following customs supervision of dangerous chemicals and dangerous goods are described separately, but it should be noted that in practice there are often intersections between the two, so if the import and export goods belong to both dangerous goods and dangerous chemicals, then the relevant regulatory requirements of customs should be taken into account to avoid omissions.
For the import and export supervision of dangerous chemicals and dangerous goods, the basic supervision logic of customs is that the import and export of dangerous chemicals need to report to customs and provide relevant declaration information according to law, and for dangerous chemicals that belong to dangerous goods at the same time, their packaging needs to meet the supervision requirements of customs for dangerous goods. (Customs supervision requirements for dangerous goods mainly focus on the performance identification and use identification of the packaging of exported dangerous goods, and for imported dangerous goods, mainly for the unity of the packaging) dangerous chemicals
1. Legal inspection of goods + quality requirements
According to the provisions of Article 6 (3) of the Regulations on the Safe Management of Dangerous Chemicals, the quality supervision, inspection and quarantine departments are responsible for the implementation of inspection of imported and exported dangerous chemicals and their packaging, that is, all dangerous chemicals are legally inspected goods, and must be subject to commodity inspection in accordance with the provisions of the import and export links. According to the "Notice on Issues Relating to the Inspection and Supervision of Import and Export of Hazardous Chemicals and Their Packaging" (General Administration of Customs Notice No. 129 of 2020, hereinafter referred to as "Notice 129") issued at the end of 2020, the import and export enterprises of hazardous chemicals shall ensure that the hazardous chemicals comply with the relevant international conventions, relevant domestic technical specifications and the relevant technical regulations of the importing countries. In addition, the import and export of dangerous chemicals used as food and food additives shall comply with the relevant food safety regulations.
2. Import supervision - "port inspection + destination inspection"
Customs inspection of imported hazardous chemicals and their packaging to adopt the "port inspection + destination inspection" mode of supervision, the consignee of imported hazardous chemicals or their agents should apply to the Customs inspection and inspection, the port customs implementation of packaging inspection, the destination customs inspection of the contents. And in accordance with the requirements of Notice 129, the consignee of imported hazardous chemicals or its agent to declare, fill in the matters should include the hazard category, packaging category (except for bulk products), the United Nations dangerous goods number (UN number), the United Nations dangerous goods packaging mark (packaging UN mark) (except for bulk products), etc., should also provide the following materials: (a) "Declaration of conformity of imported hazardous chemicals enterprises 》; (b) the need to add inhibitors or stabilizers to the product, should provide the actual addition of inhibitors or stabilizers, such as the name, quantity and other information; (c) Chinese hazard public labeling (except for bulk products), Chinese samples of safety data sheets.
3. Export supervision - "origin inspection + port inspection"
The customs adopts the supervision mode of "origin inspection + port inspection" for the export of dangerous chemicals and their packaging, the consignor or his agent of the exported dangerous chemicals shall apply to the local customs for inspection and "origin inspection", and the local customs shall issue an electronic ledger after passing the inspection. The customs office at the port of exit shall check and release the goods with the electronic ledger. And in accordance with the requirements of Notice 129, the consignor of exported hazardous chemicals or its agent to the Customs inspection, the following materials should be provided: (a) "export of hazardous chemicals manufacturers to comply with the declaration"; (b) "outbound cargo transport packaging performance test results" (except for bulk products and international regulations exempted from the use of dangerous goods packaging [3]); (c) the classification of hazardous characteristics identification report; (d) (D) the risk of public labeling (except for bulk products), safety data sheet samples, such as foreign language samples, should provide the corresponding Chinese translation; (E) the need to add inhibitors or stabilizers to the product, should provide the actual name of the added inhibitors or stabilizers, the number and other information.
Example of hazard labeling
From the perspective of customs supervision, in the import and export of hazardous chemicals, the main purpose is to review the main components/component information, physical and chemical properties, hazard category, hazard label (imported products should have Chinese hazard label), safety data sheet (imported products should be accompanied by Chinese safety data sheet), and the packaging type, packaging mark, packaging category, packaging specifications, unit weight, packaging use status, etc, Package use condition, etc. to check whether to meet the relevant requirements. It should be noted that most of the dangerous chemicals belong to dangerous goods, so the import and export should meet the supervision requirements of customs for dangerous goods at the same time.
