Takehome: Shanghai Entry-Exit Inspection and Quarantine Bureau (Shanghai CIQ) announced that a strict spot check of hazardous chemicals is coming on Oct 1st.
The Management System of Dangerous Goods of Shanghai went online on June 30th 2017. Shanghai Entry-Exit Inspection and Quarantine Bureau (Shanghai CIQ) required enterprises to notify their products through the system if they:
- Are listed in the Inventory of Hazardous Chemicals (2015); or
- Are eligible for the hazardous chemical determination principle.
From Oct 1st, Shanghai CIQ will run a 10-stage spot check that will last for almost a year on hazardous chemicals that haven’t been notified. Each stage will focus on hazardous chemicals with different UN numbers:
Fig 1. UN numbers to be inspected
The spot check will be stricter than the normal inspection. The most important materials that will be inspected are the labels and SDSs for the hazardous chemicals, along with the Compliance Statement of Enterprises that Operate Imported Hazardous Chemicals (Please see the Annex 1 of AQSIQ Announcement No.30 of 2012). Based on the previous experiences from normal daily inspection, most incompliances are associated with labeling of hazardous chemicals. The labels should contain chemical names, components, pictograms, danger signals and other information. Enterprises should double check the compliance of their labels to avoid penalties from the authority. For enterprises lacking technical ability to review their labels, the test center for industrial products and raw materials under Shanghai CIQ provides label review services. Usually speaking, if enterprises’ labels are reviewed and modified by the test center, they wouldn’t have many technical errors and it will be easier for the enterprises to cope with the spot check.
For the ordinary chemicals which are not listed in the Inventory of Hazardous Chemicals or not eligible for the hazardous chemicals determination principles, enterprises can notify with a Compliance Statement of Non-hazardous Chemicals. The hazards identification and classification report is also required.
Fig 2. Compliance Statement of Non-hazardous Chemicals