A Compliance Guide for Exporting Dangerous Goods from China: Understanding the "Dangerous Goods Packaging Certificate"
1. Overview
The "Dangerous Goods Packaging Certificate" (commonly referred to as "Wei Bao Zheng" in the Chinese logistics industry) is the collective term for two mandatory statutory procedures: the Performance Test and the Use Appraisal for export dangerous goods packaging. These inspections are conducted by China Customs, with no government fees levied. However, companies are responsible for complying with the established procedures.
2. Legal Basis
In accordance with the Law of the People's Republic of China on Import and Export Commodity Inspection and its implementing regulations:
- Manufacturers of packaging intended for exporting dangerous goods must apply to Customs for a Performance Test of the packaging.
- Manufacturers producing the dangerous goods for export must apply to Customs for a Use Appraisal of the packaged goods.
- Dangerous goods packed in packaging that has not passed the appraisal are strictly prohibited from export. Violators are subject to administrative penalties.
3. Detailed Two-Step Inspection Process
Obtaining the "certificate" involves a sequential two-step process.
Step 1: Performance Test (on the packaging itself)
Applicant: The manufacturer of the export dangerous goods packaging.
Prerequisite: The packaging manufacturer must first register with Customs to obtain a unique Manufacturer's Code (Format: C + 6 digits, which appears in the UN marking on the packaging).
Process & Documentation: The manufacturer applies for the test and submits a self-inspection report. Upon passing, China Customs issues the "Performance Test Result Sheet for Entry-Exit Goods Packaging."
Validity: The sheet is valid for a maximum of 12 months from the date of packaging production. If re-tested after expiration, the new validity period is up to 6 months from the re-test date.
Step 2: Use Appraisal (on the packed goods)
Applicant: The manufacturer of the export dangerous goods (i.e., the shipper/factory).
Required Core Documents:
- A completed and company-stamped "Application for Use Appraisal of Export Dangerous Goods Packaging" with a self-declaration of compliance.
- A valid "Performance Test Result Sheet for Entry-Exit Goods Packaging."
- (For new packaging/product combinations) A compatibility test report or self-declaration covering at least six months.
Process & Documentation: The manufacturer applies for the appraisal with the above documents. Upon passing, China Customs issues the "Use Appraisal Result Sheet for Transport Packaging of Export Dangerous Goods." This document is mandatory for booking dangerous goods shipments with carriers.
Validity Period (calculated from the date of filling/loading):
- Sea/Road Transport: 6 months for packaging containing Class 8 (Corrosive) dangerous goods; 12 months for all other classes.
- Air Transport: The Use Appraisal Result Sheet for all air cargo dangerous goods is valid for 3 months.
- Critical Rule: The validity period of the Use Appraisal Result Sheet must not exceed the validity period of the corresponding Performance Test Result Sheet.
4. Key Compliance Reminder
Companies must use packaging containers that have passed Customs appraisal. According to regulations:
- Using or providing non-appraised packaging can result in fines up to RMB 100,000.
- Using packaging that failed the appraisal for exporting dangerous goods can result in fines up to RMB 200,000.
Disclaimer: This guide provides an overview of China's Dangerous Goods Packaging Certificate requirements based on current regulations. Always consult your freight forwarder, certified dangerous goods personnel, and the latest China Customs regulations for specific compliance needs. Regulations are subject to change.