With the arrival of summer, the export demand for sunscreen spray has surged, but many foreign trade companies have their goods detained due to their lack of understanding of dangerous goods transportation regulations, causing significant losses. This article will analyze the sunscreen spray transportation certification requirements for you to avoid export “minefields”.
- Why is sunscreen spray detained by customs?
Most sunscreen sprays contain flammable propellants (such as propane and butane). According to the International Maritime Dangerous Goods Regulations (IMDG) and the Air Transport Dangerous Goods Regulations (IATA), such products are classified as Class 2.1 flammable gas dangerous goods. Failure to declare as dangerous goods will result in:
Customs detention
High fines
Entire batch of goods returned
Severe cases may be blacklisted
II. List of necessary certifications and documents
MSDS Chemical Safety Data Sheet
Must be issued by a professional organization
Contains key data such as ingredients, flash point, hazardous properties, etc.
UN38.3 test report (required for air transport)
Prove product transportation safety
Validity period is usually 18 months
Dangerous goods classification identification report
China needs to provide CNAS accredited laboratory report
EU needs to comply with CLP regulations
Packaging performance inspection form
Prove that the packaging meets UN specifications
Need to use Certified dangerous goods packaging
III. Precautions for different modes of transportation
Key points for sea transportation:
Class 2.1 dangerous goods label must be affixed
Containers require ventilation devices
Mixing with oxidants is prohibited
Special requirements for air transportation:
No more than 100ml per bottle (most airlines)
Net weight of outer packaging is usually limited to 5kg
Additional filing application for airlines is required
Rail transportation:
Comply with RID regulations
Central Asia/China-Europe trains have additional reporting requirements
IV. Analysis of common “mine-stepping” cases
Case 1: A company declared as ordinary cosmetics, without marking flammable ingredients, and the entire container was destroyed at the destination port, resulting in a loss of US$230,000.
Case 2: The packaging used ordinary cartons instead of UN-certified cylinders, and leakage occurred during transportation, resulting in the entire batch of goods being rejected by the airline.
Case 3: The flash point data in the MSDS did not match the actual measurement, which was determined to be a false declaration and the company’s credit rating was downgraded.
- Expert advice
Prepare certification documents 2-3 months in advance
Choose a freight forwarder with dangerous goods qualifications
Different countries have special regulations (such as Halal certification required in the Middle East)
Update test reports regularly (changes in ingredients require retesting)
Purchase special dangerous goods transportation insurance
- Latest regulatory developments
Starting in 2024, the EU will implement the stricter GHS 9th revised version standard, which will have new requirements for aerosol classification. The US DOT recently updated the exemption clause of 49 CFR 173.306, and some small spray products may be exempted, but they must meet strict conditions.
Conclusion: The export certification of sunscreen spray is complicated but not insurmountable. Professional matters can be handled by professional organizations, which can save a lot of time and cost. It is recommended to consult dangerous goods transportation experts before exporting, conduct compliance pre-examination, and ensure smooth customs clearance.