Overview of China’s Dangerous Goods Export Regulations: Latest Policies and Compliance Requirements

I. Overview of China’s Dangerous Goods Export Supervision System
China’s dangerous goods export supervision adopts a multi-department joint management model, mainly involving the following institutions:

General Administration of Customs: responsible for import and export customs clearance supervision

Ministry of Emergency Management: responsible for the safety management of hazardous chemicals

Ministry of Transport: responsible for transportation supervision

Ministry of Ecology and Environment: responsible for environmental risk assessment

Ministry of Commerce: management of some dangerous goods export licenses

II. Latest policy updates (2023-2024)
“Hazardous Chemicals Catalogue” 2023 revised version: 5 new controlled substances, adjustment of the classification of 3 substances

Announcement No. 78 of the General Administration of Customs in 2023: Strengthening the punishment of concealment and underreporting of dangerous goods

“Export Dangerous Goods Packaging Inspection Procedure” SN/T 0370-2023: Update packaging standard requirements

Electronic declaration system upgrade: Comprehensive implementation of the “single window” dangerous goods declaration module

III. Core compliance requirements

1. Classification and identification
   Must be in accordance with GB 30000 series standards for hazardous properties classification

A qualified laboratory must issue a “Hazardous Properties Classification Identification Report”

Mixtures must be classified by GHS and SDS (Safety Data Sheet) must be prepared

2. Export license management
   Products in the “Catalogue of Hazardous Chemicals Strictly Restricted for Import and Export in China” must apply for a license

Some hazardous goods are subject to the “Dual-Use Items and Technology Import and Export License”

New “High Concern Hazardous Chemicals” require special declarations

3. Packaging and labeling
   Must comply with SN/T 0370-2023 standards

Packaging containers must obtain the “Entry and Exit Goods Packaging Performance Test Result Sheet”

The label must include UN number, correct shipping name, hazard category label, etc.

4. Transport document requirements
   Dangerous goods transport declaration

Container/vehicle packing certificate

Comply with IMDG Code, IATA DGR and other international rules

Multimodal transport requires full compliance certification

IV. Special regulations for key industries
Export of lithium batteries:

Required to pass UN38.3 test

New thermal diffusion test requirements from 2024

9 types of dangerous goods labeling mandatory requirements

Export of chemical products:

Substances of high concern need to submit downstream use instructions

New PFAS substances pre-export registration requirements

Pesticide products:

Must also comply with the requirements of the Rotterdam Convention

New pre-export information notification obligations

V. Common risk points of violations
False declaration: dangerous goods are declared as ordinary goods

Unqualified packaging: Use of uninspected or non-standard packaging

Missing documents: Lack of necessary transportation documents or technical specifications

Wrong labeling: Hazardous signs do not meet the latest standards

Transportation violations: Failure to select a qualified carrier in accordance with regulations

VI. Compliance recommendations
Establish product compliance files, regularly update SDS and transportation documents

Choose a qualified third-party agency to conduct regular compliance audits

Pay attention to changes in target market regulations (such as EU CLP, US Hazmat, etc.)

Annual dangerous goods training for export operators

Enjoy customs clearance convenience by using customs AEO certification

VII. Violation penalties
Administrative penalties: fines up to 50% of the value of the goods

Criminal penalties: Serious violations may face criminal liability

Credit penalties: inclusion in the customs credit management blacklist

Cargo disposal: return, destruction or diversion

Enterprises should establish a complete compliance system for dangerous goods exports. It is recommended to consult professional compliance consultants or legal service agencies to ensure compliance with various regulatory requirements in China and the target market.