由 caicai8478 I. Overview
China has a strict management system for the export of dangerous goods, and packaging and labeling requirements are an important part of it. These regulations are intended to ensure the safety of dangerous goods during transportation and storage, while complying with international transportation regulations.
II. Legal Basis
Law of the People’s Republic of China on Import and Export Commodity Inspection and its Implementing Regulations
Regulations on the Safety Management of Hazardous Chemicals (State Council Decree No. 591)
International Maritime Dangerous Goods Code (IMDG Code)
International Air Transport Dangerous Goods Code (IATA DGR)
Measures for the Administration of Inspection of Export Dangerous Goods Packaging (Announcement No. 129 of the General Administration of Customs in 2020)
GB series national standards (such as GB 190, GB/T 191, etc.)
III. Classification of Dangerous Goods
According to the United Nations Recommendations on the Transport of Dangerous Goods, dangerous goods are divided into 9 categories:
Explosives
Gases
Flammable liquids
Flammable solids, substances that are prone to spontaneous combustion, substances that release flammable gases when in contact with water
Oxidizing substances and organic peroxides
Toxic substances and infectious substances
Radioactive substances
Corrosive substances
Miscellaneous dangerous substances and articles
IV. Packaging requirements
(I) Packaging type
Barrel packaging: steel barrels, aluminum barrels, plastic barrels, etc.
Box packaging: wooden boxes, plywood boxes, recycled wood boxes, fiberboard boxes, plastic boxes, etc.
Bag packaging: plastic woven bags, paper bags, composite bags, etc.
Composite packaging: a packaging form consisting of inner packaging and outer packaging
Pressure vessels: steel cylinders used to transport gases, etc.
(II) Packaging performance requirements
Sealing: must ensure no leakage
Strength: can withstand vibration, extrusion and impact under normal transportation conditions
Compatibility: packaging materials must be compatible with the dangerous goods
Protection: can prevent the contents from being damaged by changes in temperature, humidity or pressure
(III) Packaging level
Divided into three levels according to the degree of danger:
Class I packaging: highly dangerous substances
Class II packaging: moderately dangerous substances
Class III packaging: low-risk substances
(IV) Packaging inspection
Performance inspection: including drop test, stacking test, airtight test, etc.
Use identification: check whether the actual use of the packaging meets the requirements
Periodic inspection: packaging manufacturers need to conduct regular inspections
V. Label requirements
(I) Dangerous goods label
Basic elements:
Dangerous goods category/item number
Graphic symbol
Text description (such as “flammable liquid”, “toxic”, etc.)
Background color and symbol color meet the standard requirements
Dimension requirements:
Minimum size: 100mm×100mm
Rhombus shape
Inner edge width ≥2mm
Paste requirements:
Must be firmly pasted in a conspicuous position on the package
Must not be covered by other labels
All relevant hazard labels must be displayed on the same package
(II) Transport label
United Nations number (UN number): 4 digits
Correct transport name
Shipper and consignee information
Net weight and gross weight
Emergency contact number
(III) Special labeling requirements
Marine pollutant mark: Applicable to marine pollutants defined in the IMDG rules
Directional arrow: Some liquid dangerous goods need to be marked “this side up”
Limited packaging mark: Applicable to dangerous goods transported in limited quantities
VI. Marking requirements
United Nations packaging symbol:
text
UN
X/Y/Z
Country code
Year of production
Manufacturer code
Packaging type code
X: Packaging category (I, II or III)
Y: Relative density (liquid) or maximum gross weight (solid)
Z: Hydraulic test pressure (kPa)
Other marks:
“Recycling ” or “reusable” mark (if applicable)
Packaging production date
Special operating instructions
VII. Special requirements
Lithium battery:
A lithium battery operation label is required
Indicate the watt-hour or lithium content
Comply with UN38.3 test requirements
Limited quantity packaging:
Use limited quantity mark
Inner packaging has strict limit requirements
Exceptional quantity packaging:
Use “EQ” mark
Exempt from some transportation requirements
VIII. Export process
Packaging selection: Select appropriate packaging according to the nature of dangerous goods
Packaging inspection: Conducted by an inspection agency approved by the customs
Label production and affixing Paste: Make according to the standard and paste correctly
Declare inspection: Apply to the customs for the identification of the use of export dangerous goods packaging
Obtain certificate: After passing the qualification, obtain the “Identification Result Sheet for the Use of Export Dangerous Goods Transport Packaging”
Declare export: Go through customs declaration procedures with the identification result sheet
IX. Common problems and precautions
Common mistakes:
Use uninspected packaging
Label size and color do not meet the standards
Missing necessary markings
Packaging level does not match the dangerous goods level
Precautions:
Different modes of transportation (sea, air, land) may have additional requirements
Importing countries may have additional regulations
Labels must be made of durable materials to ensure that they do not fall off or fade during transportation
Regularly pay attention to regulatory updates, especially the biennial revision of the United Nations TDG
X. Penalties for violations
Violations of the export packaging and labeling requirements for dangerous goods may result in:
Return of goods
Administrative penalties
Criminal liability (when serious consequences occur)
Being included in the customs list of dishonest enterprises
Conclusion
China’s export packaging and labeling requirements for dangerous goods are strict and complex. Enterprises should fully understand and comply with relevant regulations. If necessary, they can seek help from professional organizations to ensure smooth exports and compliance with domestic and international regulations.