Port of Hamburg, Germany: EU Customs New Regulations and Special Procedures for Dangerous Goods Declaration

As one of Europe’s largest ports and a core hub for dangerous goods transportation within the EU, the Port of Hamburg (Hafen Hamburg) handles over 1.2 million twenty-foot equivalent units (TEUs) of dangerous goods annually, covering categories such as chemical raw materials, lithium batteries, and compressed gases, accounting for 23% of Europe’s total maritime dangerous goods volume. In March 2024, the EU officially implemented the Union Customs Code Modernization (UCC 2.0) and the Supplementary Directive on Maritime Safety of Dangerous Goods, comprehensively upgrading the dangerous goods declaration procedures, customs inspection standards, and corporate compliance requirements at the Port of Hamburg. According to statistics from the Port of Hamburg Authority, after the new regulations took effect, the rejection rate for dangerous goods declarations by enterprises unfamiliar with the procedures rose from 8% to 22%, with average customs clearance time extending by 1.5 days. In contrast, compliant enterprises maintained a customs inspection pass rate of over 95%. This article focuses on the customs supervision requirements and special dangerous goods declaration procedures at the Port of Hamburg under the new EU regulations, combining practical cases to provide enterprises with a full-process guide from “new regulation interpretation to procedure implementation and risk avoidance.”

I. Core Impacts of the EU Customs New Regulations (UCC 2.0) on the Port of Hamburg

Centered on “digital supervision, risk pre-positioning, and full-cycle traceability,” the EU’s UCC 2.0 introduces a series of mandatory requirements for the declaration, inspection, and release of dangerous goods at the Port of Hamburg. Its impacts primarily focus on three dimensions—”declaration timelines, data standards, and inspection mechanisms”—directly transforming the traditional dangerous goods customs clearance model.

(1) Declaration Timelines: From “Post-Arrival Declaration” to “Pre-Shipment Pre-Verification”

The new regulations explicitly require that complete declaration documents for dangerous goods must be submitted to the Port of Hamburg Customs 24 hours before shipment, replacing the traditional “24 hours after arrival.” Additionally, declarations must undergo online pre-verification via the EU’s unified Entry Summary Declaration (ESD) system. Goods failing pre-verification are prohibited from being loaded onto ships. Specific timeline requirements are as follows:

• General Dangerous Goods (e.g., Class 3 Flammable Liquids, Class 8 Corrosive Substances): Submit ESD declarations 24 hours before shipment. Customs will provide pre-verification results within 12 hours; shipment can only be arranged upon approval.
• High-Risk Dangerous Goods (e.g., Class 1 Explosives, Class 7 Radioactive Substances): Submit ESD declarations 48 hours before shipment, with an additional “Dangerous Goods Safety Assessment Report” (issued by an EU-accredited third-party organization). Customs pre-verification time is extended to 24 hours.
• Emergency Dangerous Goods (e.g., medical compressed oxygen, disaster relief chemicals): An “emergency declaration channel” may be applied for, with a minimum declaration timeline of 6 hours before shipment. However, “proof of emergency need” (e.g., hospital prescriptions, government disaster relief letters) must be submitted, and 100% on-site customs inspection is mandatory.

Practical Case: In May 2024, a Chinese chemical enterprise exporting a batch of Class 3 flammable liquids to the Port of Hamburg failed to submit the ESD declaration 24 hours in advance. Upon arrival, the goods were detained by customs, incurring demurrage fees of €800 per day (for 3 days total). The enterprise also had to rebook shipment, leading to delivery delays and customer penalty losses exceeding €5,000.

(2) Data Standards: Unified “Dangerous Goods Digital Twin File”

The new regulations mandate that dangerous goods declarations at the Port of Hamburg must establish a “digital twin file,” integrating full-lifecycle cargo data. The data format must comply with the EU’s Dangerous Goods Data Exchange Standard (DGDS v3.0) to achieve “one declaration, full-cycle reuse.” A digital twin file must include the following core data:

1. Basic Cargo Information: UN Dangerous Goods Number (UN No.), dangerous goods class and division, packaging category (e.g., I, II, III), net and gross weight, and packaging material (must indicate compliance with IMDG Code requirements).
2. Safety Data: Safety Data Sheet (SDS, must be in EU official languages—at minimum German and English), emergency response measures (e.g., leakage handling, fire suppression methods), and exposure limits (e.g., TLV-TWA, PEL values).
3. Transport Chain Data: Port of loading, transshipment port, port of discharge (specific terminals at the Port of Hamburg, such as Altona Terminal or Burchardkai Terminal must be specified), transport vehicle information (ship IMO number, container ISO code), and carrier qualification number (must be registered with EU Customs).
4. Traceability Data: Cargo production batch number, production date, shelf life (if applicable), EU Registration Number (EORI number) of the manufacturing enterprise, and EU VAT number of the receiving enterprise.

Data Verification Requirements: The Port of Hamburg Customs uses a “Dangerous Goods Data Verification System” to automatically cross-check declared data against databases of the IMDG Code (International Maritime Dangerous Goods Code) and EU REACH Regulation (Registration, Evaluation, Authorization and Restriction of Chemicals). If data conflicts are detected (e.g., mismatched UN No. and cargo class), the system automatically rejects the declaration and provides correction guidance. Enterprises must revise and resubmit data within 4 hours.

(3) Inspection Mechanism: Dual Model of “Risk Classification + Intelligent Inspection”

Under the new regulations, Hamburg Customs no longer uses “random sampling” for dangerous goods inspections. Instead, inspection rates are determined based on a “risk classification model,” with “intelligent inspection equipment” introduced to improve efficiency. The specific mechanism is as follows:

• Risk Classification Standards: Customs assigns inspection rates based on three dimensions—”cargo risk level (high/medium/low), enterprise compliance level (A/B/C), and transport chain stability”:
• High-risk cargo (e.g., Class 1 Explosives) + Class C compliant enterprises: 100% inspection rate;
• Medium-risk cargo (e.g., Class 5 Oxidizers) + Class B compliant enterprises: 30% inspection rate;
• Low-risk cargo (e.g., Class 9 Miscellaneous Dangerous Goods) + Class A compliant enterprises: 5% inspection rate.
• Intelligent Inspection Equipment: The Port of Hamburg has equipped 6 dedicated dangerous goods terminals (e.g., Tollerort Terminal, Waltershof Terminal) with “CT scanning inspection cabins” and “dangerous goods gas detection gates,” enabling:
• Non-intrusive inspection: CT scanning directly checks the integrity of cargo packaging inside containers, avoiding seal damage from opening (suitable for volatile or corrosive dangerous goods);
• Real-time gas monitoring: Detection gates identify toxic gas leaks (e.g., chlorine, ammonia) from containers within 2 seconds; cargo with excessive concentrations is isolated for treatment;
• Data synchronization: Inspection results are uploaded to the EU Customs Database in real time. Enterprises can view inspection progress and results via the ESD system without on-site waiting.

II. Special Procedures for Dangerous Goods Declaration at the Port of Hamburg: Full-Process Breakdown from “Declaration to Inspection to Release”

Based on the new EU regulations and the Port of Hamburg’s layout (e.g., dedicated dangerous goods terminals, isolated storage areas), a special “three-phase, six-step” declaration process has been developed. Each phase requires strict compliance; otherwise, declaration failure or cargo detention risks arise.

(1) Phase 1: Declaration Preparation (48–24 Hours Before Shipment)

The core of this phase is completing “data preparation + qualification verification” to ensure declaration documents meet EU DGDS standards and the Port of Hamburg’s specific requirements. Specific steps are as follows:

Step 1: Confirm Cargo Classification and Packaging Compliance

• Classification Confirmation: Determine the dangerous goods class, division, and UN No. in accordance with the IMDG Code 2024. For example, lithium batteries must be distinguished between “lithium metal batteries (UN 3090)” and “lithium-ion batteries (UN 3480),” as their declaration requirements differ.
• Packaging Compliance: Packaging must meet the “Port of Hamburg Dangerous Goods Packaging Standards,” such as:
• Class 3 Flammable Liquids: Must use “leak-proof metal drums” (thickness ≥1.2mm) with double-sealed lids;
• Class 7 Radioactive Substances: Must use “lead-shielded packaging” with a surface radiation dose rate ≤2mSv/h (a third-party test report must be provided).
• Labeling Requirements: EU standard dangerous goods labels (size ≥100mm×100mm) must be affixed to packaging, including class symbols, UN No., and emergency contact number (must be an EU-based number). Labels must be waterproof and wear-resistant. Hamburg Customs inspects label integrity; damaged labels must be reaffixed on-site.

Step 2: Prepare Declaration Documents and Digital Twin File

• Basic Documents: ESD declaration form (download template from the Port of Hamburg Customs official website), commercial invoice (must indicate “dangerous goods” and UN No.), packing list (itemize quantity and weight of dangerous goods per container), and SDS (must include German translation, certified by the manufacturing enterprise’s seal).
• Special Documents:
• For “limited quantity dangerous goods” (e.g., small-packaged chemical samples): Submit a “limited quantity exemption certificate” (in accordance with IMDG Code Chapter 3.4);
• For cargo transshipped via the Port of Hamburg to other EU countries (e.g., France, Italy): Submit a “transshipment permit application” specifying transshipment port and transport vehicle information.
• Digital Twin File Upload: Upload the digital twin file via the Port of Hamburg’s “Dangerous Goods Declaration Portal (Hamburg DG Portal).” The system automatically verifies data format; documents with format errors must be revised within 2 hours, otherwise subsequent declarations will be affected.

Step 3: Qualification Verification (Enterprise and Carrier)

• Enterprise Qualifications: Declaring enterprises must hold “EU dangerous goods import/export qualifications” (i.e., EORI number + dangerous goods business license) and be registered with Port of Hamburg Customs (registration takes 3 working days; business license and SDS preparation capability proof must be submitted).
• Carrier Qualifications: Ships transporting the cargo must hold “EU dangerous goods transport qualifications” (IMO Dangerous Goods Ship Code). Containers must be “Port of Hamburg-approved dedicated dangerous goods containers” (marked with “DG Approved” and subject to pre-loading leak tests; test reports must be submitted with declaration documents).

(2) Phase 2: Declaration Submission and Pre-Verification (24 Hours Before Shipment – Shipment)

The core of this phase is submitting declaration documents via the ESD system and cooperating with customs for pre-verification. Specific steps are as follows:

Step 4: Online ESD Declaration Submission and Pre-Verification Tracking

• Submission Channel: Log in to the EU ESD system (https://ec.europa.eu/taxation_customs/dds2/esd/main.jsp), select “Port of Hamburg Customs” as the declaring customs, and upload all documents (supports PDF and XML formats). After submission, the system generates a “declaration number” (save for future inquiries).
• Pre-Verification Tracking: Pre-verification takes 12 hours for general dangerous goods and 24 hours for high-risk dangerous goods. Enterprises can track pre-verification status in real time via the Port of Hamburg’s “Hamburg DG Portal”:
• “Pre-Verification Approved”: The system sends a confirmation email; shipment can be arranged using the declaration number;
• “Pre-Verification Pending Supplement”: Customs lists required supplementary documents (e.g., missing German SDS); enterprises must submit supplements within 4 hours, otherwise the declaration becomes invalid;
• “Pre-Verification Rejected”: Declaration documents must be revised (e.g., incorrect cargo classification); re-submission resets the pre-verification timer (risking shipment delays).

Step 5: Pre-Shipment On-Site Verification (Exclusive to High-Risk Dangerous Goods)

High-risk dangerous goods (e.g., Class 1 Explosives, Class 7 Radioactive Substances) require on-site inspection by the Port of Hamburg’s “Dangerous Goods On-Site Verification Team” (composed of customs officers, port safety experts, and third-party testing institutions) before shipment. Verification content includes:

• Consistency between cargo packaging and declared documents (e.g., packaging material, sealing status);
• Compliance of dangerous goods labels (visibility, completeness of information);
• Availability of emergency equipment (e.g., fire extinguishers, chemical protective suits – must be immediately accessible on transport vehicles);
• Compliance of driver qualifications (must hold an EU dangerous goods transport license, valid and in-date).

Upon passing verification, the team issues a “Shipment Permit Certificate,” allowing cargo to enter dedicated dangerous goods terminals for loading. Failed verification requires rectification and re-application (maximum rectification time: 24 hours).

(3) Phase 3: Post-Arrival Inspection and Release (0–24 Hours After Arrival)

The core of this phase is cooperating with customs for inspection to ensure cargo meets all requirements. Specific steps are as follows:

Step 6: Post-Arrival Inspection and Release

• Inspection Notification: Customs sends an “Inspection Notice” via the ESD system, specifying inspection time, location (e.g., Tollerort Dangerous Goods Inspection Area), and required documents (e.g., Shipment Permit Certificate, test reports). Enterprises must arrive at the inspection site 1 hour in advance.
• Inspection Types:
• Routine Inspection: Verifies consistency between cargo packaging, labels, quantity, and declarations; takes 1–2 hours;
• Intelligent Inspection: Uses CT scanning and gas detection equipment; takes approximately 30 minutes with real-time results;
• Laboratory Testing: Samples suspected non-compliant cargo (e.g., SDS inconsistent with actual composition) for testing at the Port of Hamburg Customs Laboratory; takes approximately 24 hours, with testing fees borne by the enterprise (€500–€1,000 per sample).
• Release and Follow-Up: Upon passing inspection, customs marks “Released” in the ESD system. Enterprises can arrange cargo pickup or transshipment using the release notice. Failed inspection results in cargo being moved to a “Dangerous Goods Isolated Storage Area” (storage fee: €150 per container per day). Enterprises must complete rectification (e.g., repackaging, supplementary documents) within 3 days; otherwise, customs reserves the right to dispose of the cargo (e.g., destruction, return shipment) in accordance with laws.

III. Risk Mitigation and Compliance Recommendations for Dangerous Goods Declaration at the Port of Hamburg

Under the new EU regulations, compliance risks for dangerous goods declarations at the Port of Hamburg have significantly increased. Enterprises must establish risk mitigation mechanisms from three aspects—”process optimization, qualification management, and emergency preparedness”—to minimize risks of declaration failure, cargo detention, and fines.

(1) Process Optimization: Establish “Advanced Planning + Data Verification” Mechanisms

• Advanced Declaration Planning: Begin declaration preparation 72 hours before shipment to allow sufficient time for addressing data errors and document supplements, avoiding delays due to time constraints.
• Automated Data Verification: Use “EU DGDS Data Verification Tools” (e.g., free online tools provided by the Port of Hamburg) to automatically verify data format and logic (e.g., UN No.-class consistency, SDS compliance with EU standards) before ESD submission, reducing pre-verification rejection rates.
• Carrier Collaboration: Confirm carrier qualifications and container compliance with shipping companies and freight forwarders in advance to avoid declaration failure due to carrier issues (e.g., ships lacking dangerous goods transport qualifications). Prioritize high-quality carriers registered with the Port of Hamburg (e.g., Hapag-Lloyd, Maersk).

(2) Qualification Management: Ensure Full-Chain Qualification Compliance

• Enterprise Qualification Maintenance: Regularly check the validity of EORI numbers and dangerous goods business licenses; apply for renewal 30 days in advance. Update Port of Hamburg Customs registration information (e.g., enterprise address, contact details changes) promptly to avoid declaration rejection due to inconsistent information.
• Personnel Qualification Training: Arrange employees responsible for dangerous goods declarations to attend “Port of Hamburg Dangerous Goods Declaration Training” (regularly organized by the Port of Hamburg Authority, with certification upon completion) to ensure familiarity with UCC 2.0, DGDS standards, and Port of Hamburg’s special procedures.
• Third-Party Collaboration: Partner with EU-accredited third-party organizations (e.g., TÜV Germany, SGS Switzerland) to commission SDS preparation and dangerous goods safety assessment reports, ensuring documents meet EU standards and reducing risks of non-compliant documentation.

(3) Emergency Preparedness: Develop “Declaration Failure – Cargo Detention” Contingency Plans

• Declaration Failure Contingency: Prepare “alternative declaration plans” in advance. For example, if pre-verification fails via the regular channel, apply for the “emergency declaration channel” (prepare proof of emergency need in advance); if cargo cannot be shipped on time, coordinate with shipping companies to reschedule (rebooking fee: approximately €1,000–€2,000 per container).
• Cargo Detention Contingency: Sign “priority storage agreements” with operators of the Port of Hamburg’s “Dangerous Goods Isolated Storage Areas” to ensure timely access to storage in case of detention, avoiding additional fines due to unavailable storage space. Meanwhile, establish contacts with local dangerous goods disposal companies (e.g., BASF Germany’s Dangerous Goods Disposal Division) to arrange rapid return shipment or destruction if cargo cannot be rectified (return shipment fee: approximately €3,000 per container; destruction fee: approximately €2,000 per container).
• Dispute Resolution: If disagreeing with customs inspection