In late June 2019, the General Administration of Customs of China (GACC) issued a notice , making official commitments to better-regulated and more stringent inspections on imported and exported dangerous goods and their packaging. This move aims to reinforce previous institutional efforts and enable safer cross-border commerce of dangerous goods.
Back in early 2012, the former General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) released the Announcement on Questions Regarding the Inspection on Imported and Exported Hazardous Chemicals and Their Packaging (AQSIQ Announcement No. 30 of 2012, see CL translation ), reiterating compulsory requirements for inspections on imported or exported hazardous chemicals and their packaging and specifying documents required for customs clearance of such goods.
Later in mid-2015, in the wake of a series of shocking accidents caused by hazardous chemicals, the AQSIQ launched the “Two 100%” initiative: 100% of imported hazardous chemicals are subject to on-site safety inspection and 100% of imported hazardous chemicals are subject to sampling and lab tests (see CL news ).
However, with these arrangements in place, authorities still perceive the necessity and urgency of imposing more stringent controls in this regard, and thus have proposed the following measures in the notice:
- Increase relevant personnel’s understanding of safety management of dangerous goods and hazardous chemicals by organizing them to learn requirements for inspections on exported dangerous goods in the Law on Import and Export Commodity Inspection  and its implementation rules and requirements for inspections on imported and exported hazardous chemicals in the Regulations on the Control over Safety of Hazardous Chemicals (Decree 591, see CL Chempedia ).
- Carry out inspections on imported and exported hazardous chemicals listed in the 2015 Inventory of Hazardous Chemicals (see CL translation ) and their packaging in strict accordance with AQSIQ Announcement No. 30 of 2012; the approach to assess conformity can be adjusted depending on specific goods.
- Strictly ensure that imported hazardous chemicals and their packaging be subject to “checks and inspections at ports & inspections at destinations”: for imported hazardous chemicals in bulk, they should be subject to inspections at ports of entry; for imported hazardous chemicals in packaging, customs at ports of entry should inspect their packaging in accordance with relevant technical specifications, and customs at destinations should inspect the contents.
- Strictly ensure that exported hazardous chemicals and their packaging be subject to “inspections at places of origin & checks and inspections at ports”: customs at places of origin should inspect contents and packaging of such chemicals in line with relevant technical specifications; customs at ports of exit should conduct checks and inspections on packaging and conformity between goods and documents, among other items.
- Enforce strict requirements for inspections on packaging of exported dangerous goods at places of origin: customs at places of origin should verify the performance and usability of their packaging in accordance with relevant technical specifications, to ensure that the contents are in conformity with goods declared by exporters and that appropriate packaging is used.
- Exercise tight controls over qualifications of inspection personnel for imported and exported dangerous goods and their packaging: customs offices directly under GACC should strengthen the workforce for inspection on imported and exported dangerous goods and their packaging when needed, and strictly forbid unqualified personnel from engaging in the inspection work; learning and training sessions should be offered to sharpen their expertise and capabilities.
- Strictly ensure unity in various aspects, including the catalog of assessment documents for hazard classification of dangerous goods, standards of hazard classification, formats of classification reports, use of classification reports, etc.
- Strictly ensure safety of on-site inspection personnel: relevant safety protection facilities should be in place, contingency plans for handling hazardous chemicals should be further improved, emergency supplies and exercises should be enhanced, and emergency actions and inter-agency coordination should be conducted, so as to consolidate the capability of ports to cope with contingencies.
- Customs offices directly under GACC should, based on their respective conditions, enhance their safety risk controls, create a more favorable business environment at ports, leverage the mechanism for jointly controlling safety risks at ports, and properly handle problems concerning quality and safety of imported and exported dangerous goods and their packaging. Where any major problem occurs, they should promptly report to the Department of Commodity Inspection of GACC.
Sources say that Shanghai port is developing detailed rules based on the Notice to facilitate the implementation of arrangements made by the GACC. ChemLinked will present a webinar to prepare businesses for latest regulatory measures as soon as official documents are published. Please stay tuned.
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