A Shipper's Guide: New China Customs Regulations for Import/Export of Hazardous Chemicals (Effective 2020)
For International Buyers Sourcing from China
If you are purchasing chemical products from China, understanding the latest regulatory updates from China Customs is crucial for ensuring smooth logistics and compliance. This guide outlines the key requirements based on the "Announcement No. 129 of 2020" issued by the General Administration of Customs of China (GACC), which standardizes the inspection and supervision of imported and exported hazardous chemicals and their packaging.
Core Principle
China Customs is now the authority responsible for inspecting all hazardous chemicals (those listed in China's Hazardous Chemicals Directory) and their packaging during import and export procedures.
Mandatory Documentation for All Shipments
Regardless of import or export, the following documents are mandatory and must be prepared accurately:
- Safety Data Sheet (SDS) and Label: These are non-negotiable.
- Declaration of Conformity: A formal document declaring the consistency of the shipment with international regulations.
Key Differences Between IMPORT to China and EXPORT from China
The requirements for SDS/Labels and the Declaration of Conformity differ based on shipment direction. Failure to comply will lead to customs clearance delays, rejection, or penalties.
| Aspect | IMPORT into China | EXPORT from China |
|---|---|---|
| SDS & Label Standard | Must comply with Chinese National Standards (GB Standards). | Must comply with the regulations of the destination country/region (e.g., GHS, OSHA HazCom, CLP). |
| Declaration of Conformity Content | Declares that the hazard classification and packaging group align with international regulations (like the UN Model Regulations), and that the SDS/Label meets Chinese standards. | Declares that the hazard classification and packaging group align with international regulations, and that the SDS/Label meets the destination market's standards. |
| Additional Export-Specific Documents | Not applicable. |
1. Hazard Classification Identification Report: Mandatory. Issued by a GACC-approved inspection body. 2. Packaging Certificates: - Performance Test Result Sheet for Transport Packaging - Use Appraisal Result Sheet for Transport Packaging of Dangerous Goods (Note: Not required for bulk shipments or when exempted per international regulations.) |
Critical Action Points for Shippers/Consignees
For Importers (Bringing goods into China): Ensure your Chinese supplier or agent provides you with a China-GB compliant SDS and Label. The documents submitted to Customs must be in Chinese or professionally translated to meet GB standards, not mere simple translations.
For Exporters/Senders (Shipping from China): You must provide your Chinese supplier/freight forwarder with the destination country's compliant SDS and Label. Your forwarder will use these to apply for the mandatory Hazard Classification Identification Report and manage the packaging certification process.
For Products Requiring Stabilizers/Inhibitors
A statement detailing the actual name and quantity of the additive is required.
Part 14 of SDS
Pay close attention to Section 14 (Transport Information) of the SDS, as it is critical for logistics classification.
Logistics Implications
This regulation reinforces that hazardous chemical shipments are highly specialized. As an international buyer, you must:
- Verify Compliance Early: Confirm SDS/Label standards with your supplier at the procurement stage.
- Engage Expert Partners: Work with freight forwarders and agents in China who have specific expertise in hazardous materials (HAZMAT) logistics and customs clearance. They can manage the complex documentation, testing, and certification processes on your behalf.
- Plan for Lead Time: The process of obtaining the Hazard Classification Identification Report and packaging certifications adds to the total shipping lead time. Factor this into your supply chain planning.