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Professional DG Cargo Shipping From China: Key Inspection and Regulatory Points for the Use Assessment of Plastic Drums and Jerricans in Export Shipments

Introduction: Packaging for dangerous goods serves as the primary defense for safe transportation. This article outlines the core regulatory requirements and operational focuses of the Customs "Use Assessment" inspection for plastic drums and jerricans used for exporting dangerous goods.

1. Definitions: Plastic Drums vs. Jerricans

  • Plastic Drum: Typically refers to a cylindrical packaging made of plastic with flat or convex ends.
  • Plastic Jerrican: Typically refers to a packaging made of plastic with a rectangular or polygonal cross-section.

Both are common types of packaging for dangerous goods in industries such as chemicals, pharmaceuticals, and pesticides, with common capacities ranging from 1L to 450L.

2. Inspection Process and Disposition of Results

The manufacturing enterprise must apply to the local Customs for a "Use Assessment" of the packaging after passing its internal inspection. Customs will conduct a sampling inspection based on the declared quantity and proceed as follows:

  • Passed Inspection: Customs issues an electronic record and the Result Sheet for Use Assessment of Transport Packaging for Exported Dangerous Goods.
  • Failed Inspection: Customs issues a Notification of Non-compliance for Export Goods, and the goods are prohibited from export.
  • Passed after Rectification: Upon technical correction of the non-conformities and re-inspection, Customs will issue the relevant compliance certificates mentioned above.

3. Core Inspection and Regulatory Points

During the Use Assessment, Customs focuses on the following four key areas:

3.1. Documentation Requirements for Inspection Application

The enterprise must submit a complete and valid set of application documents, including: the manufacturer's inspection sheet, the original Result Sheet for Performance Test of Packaging for In/Outbound Goods, the hazard classification identification report, etc. The declaration information must be consistent with the documents. Additionally:

  • For plastic containers used for the first time, a compatibility test report or a compatibility self-declaration must be provided.
  • For liquid dangerous goods to be transported by air, a pressure leakage test report for each packaging is required.

3.2. Verification of the UN Marking

The UN marking on the packaging must be checked for compliance:

  • Content Accuracy: The marking must be consistent with the Performance Test Result Sheet. The packaging type, material code, and performance level (e.g., Packing Group I, II, III) must meet the regulatory requirements for the substance being packed (e.g., the package performance level cannot be lower than required). For liquids, the maximum permissible density marked (e.g., "1.2") must not be less than the actual density of the substance.
  • Marking Legibility and Durability: The marking must be appropriately located, of adequate size, legible, and durable enough to withstand normal transportation conditions.

3.3. Inspection of Packaging Condition and Practices

A physical inspection of the sampled packages is conducted, focusing on:

  • Integrity: The container must show no damage, deformation, leakage, or signs of contamination.
  • Cleanliness: Surfaces must be free from residues to prevent cross-contamination.
  • Closure Integrity: Sealing devices such as threaded closures, locking rings, etc., must be securely fastened. Any applied seals must be intact.
  • Filling Compliance: The net weight per package must not exceed the limits set by relevant regulations (e.g., the UN Model Regulations). The filling degree for liquids must generally not exceed 98% of the container capacity. For substances with a high coefficient of expansion, sufficient ullage (outage) must be provided to prevent leakage due to thermal expansion during transport.

3.4. Verification of Hazard Labels

Labels affixed to the exterior of the package must comply with:

  • Transport Hazard Label: A diamond-shaped hazard label corresponding to the primary hazard of the contents must be affixed. The minimum size is 100mm x 100mm (may be reduced for small packages, but symbols and text must remain legible).
  • GHS Hazard Pictogram and Label: For hazardous chemicals, a Globally Harmonized System (GHS) compliant hazard communication label must also be affixed. It must include elements such as the signal word, hazard statements, precautionary statements, pictograms, product identifier, and supplier information, all matching the declaration details.

Key Takeaway: Proper packaging compliance is essential for successful dangerous goods export shipments from China. Ensure your plastic drums and jerricans meet all UN marking, documentation, and labeling requirements before Customs inspection.

Disclaimer: This guide provides general information based on China Customs regulations and international dangerous goods standards. Always consult certified dangerous goods personnel, your freight forwarder, and the latest regulatory editions for specific packaging compliance requirements.

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