Sea Freight for Chemicals Is No Easy Task: Unveiling Dangerous Goods Declaration, MSDS Documents, and Access Policies of Different Countries

I. Preface: The Specificity and Risk Challenges of Chemical Sea Freight

As a “special category” in cross-border trade, the sea freight of chemicals involves complex safety regulations, document requirements, and policy barriers. According to 2024 data from the International Maritime Organization (IMO), over 1 billion tons of chemicals are transported by sea worldwide each year, with 30% of them falling into the category of dangerous goods. Incidents of cargo detention or hold-up due to incorrect declaration, incomplete documents, or non-compliance with policies account for 18%, and the average economic loss per incident exceeds $50,000.

Unlike ordinary cargo, chemical sea freight must meet three standards simultaneously: “transportation safety,” “environmental protection requirements,” and “target country access.” Some chemicals have flammable, explosive, corrosive, or other hazardous properties, requiring special packaging and protection during transportation. The Material Safety Data Sheet (MSDS) serves as the “identity document” of chemicals, and the completeness of its content directly determines whether customs clearance can be completed smoothly. Moreover, different countries have significantly different access policies for chemicals—such as the EU’s REACH Regulation, the US TSCA Certification, and China’s GB Standards—all setting strict thresholds for chemical sea freight. This article will break down the core points and practical skills of chemical sea freight from three dimensions: dangerous goods declaration process, MSDS document standards, and access policies of various countries, helping enterprises avoid risks and improve transportation efficiency.

II. Dangerous Goods Declaration: The “Safety Pass” for Chemical Sea Freight

The primary step in chemical sea freight is the declaration of dangerous goods, which is crucial for ensuring transportation safety and complying with international maritime regulations. According to the International Maritime Dangerous Goods Code (IMDG Code), all chemicals with hazardous properties (such as flammable liquids, corrosive substances, and toxic substances) must go through a formal declaration process to clarify the cargo’s hazard category, packaging grade, and emergency measures. Otherwise, risks such as ship refusal to load and port cargo detention will arise.

1. Classification and Identification of Dangerous Goods: The “Prerequisite” for Declaration

(1) Hazard Category Classification in the IMDG Code

The IMDG Code classifies dangerous goods into 9 major categories, each subdivided into several items. Common categories for chemicals include:

• Class 3: Flammable Liquids (e.g., ethanol, paint, methanol, with a closed-cup flash point ≤ 60°C);
• Class 8: Corrosive Substances (e.g., sulfuric acid, sodium hydroxide solution, which have the property of corroding metals or skin);
• Class 6: Toxic Substances (e.g., pesticides, formaldehyde solution, which are toxic to humans or the environment);
• Class 9: Miscellaneous Dangerous Substances and Articles (e.g., lithium batteries, asbestos products, which have other unlisted hazardous properties);

Enterprises must first determine the hazard category and UN number of chemicals through professional testing institutions (such as SGS and Intertek) (e.g., UN1170 for ethanol, UN1830 for sulfuric acid), which serve as the core basis for subsequent declarations.

(2) Common Misunderstanding: The Risk of Misjudging “Non-Dangerous Goods”

Due to a lack of professional knowledge, some enterprises mistakenly classify chemicals with potential hazards as “ordinary cargo,” such as:

• Flammable liquids with a flash point of 61-93°C (e.g., certain paint thinners), which, although not belonging to Class 3 flammable liquids, must be declared as “dangerous goods in limited quantities”;
• Cleaners containing toxic components (e.g., chlorine-containing disinfectants), which, despite low risks in daily use, still fall under Class 6 toxic substances and require compliant declaration;

Such misjudgments may lead to safety accidents during transportation or cargo detention during port inspections. Enterprises will have to bear additional costs for re-declaration and cargo destruction (with an average loss of over $30,000 per misjudgment incident).

2. Dangerous Goods Declaration Process and Required Documents

(1) Declaration Process: From “Enterprise Declaration” to “Port Review”

The formal dangerous goods declaration process usually includes the following steps:

1. Enterprise Submits Declaration Materials: Provide the Dangerous Goods Declaration Form, MSDS document, Packaging Performance Inspection Result Sheet, and Dangerous Goods Packaging Use Appraisal Result Sheet to the freight forwarder or shipping company;
2. Shipping Company Review: The shipping company verifies the cargo’s hazard category and the ship’s carrying capacity (e.g., whether the ship is equipped with corresponding dangerous goods cabins and fire-fighting equipment). After passing the review, a Booking Confirmation is issued;
3. Port Maritime Department Filing: Before cargo loading, submit declaration information through the port maritime department system. The maritime department conducts on-site inspections of packaging integrity and label standardization, and issues a Dangerous Goods Shipment Permit upon qualification;
4. Loading and Tracking: The cargo is loaded into the designated dangerous goods cabin at the specified time. The shipping company issues a bill of lading (B/L) containing dangerous goods information, and the enterprise must retain the declaration documents for subsequent inspections.

(2) Requirements for Core Declaration Documents

• Dangerous Goods Declaration Form: Clearly fill in the cargo name, UN number, hazard category, packaging grade, quantity, gross weight, and packaging specifications (e.g., “100 barrels, 20L per barrel, UN1170, Class 3 dangerous goods, Class II packaging”);
• Packaging Performance Inspection Result Sheet: Issued by domestic quality inspection institutions (such as local entry-exit inspection and quarantine bureaus), it certifies that packaging containers (e.g., iron barrels, plastic barrels) meet dangerous goods packaging standards and have sufficient impact resistance and leak-proof capabilities;
• Dangerous Goods Packaging Use Appraisal Result Sheet: Certifies that the packaging containers have been correctly loaded with chemicals, are tightly sealed, and have clear labels (e.g., pasting dangerous goods labels and UN number labels);

These documents must ensure consistency in content. For example, the UN number in the Dangerous Goods Declaration Form must completely match that in the MSDS document; otherwise, the port review will not be approved.

3. Common Declaration Issues and Countermeasures

(1) Non-Compliant Packaging: The “Main Cause” of Declaration Failure

Packaging issues are the primary cause of dangerous goods declaration failure, such as:

• Packaging containers failing to pass performance inspection (e.g., plastic barrels with insufficient corrosion resistance, unable to hold sulfuric acid);
• Non-standard packaging labels (failing to paste hazard category labels or having blurred labels);
• Overloading (e.g., a 20L iron barrel loaded with 25L of flammable liquid, exceeding the maximum carrying capacity of the packaging);

Countermeasures: Enterprises should select packaging suppliers that meet IMDG Code standards, conduct leak tests (such as air pressure tests and inversion tests) before loading, and have professional personnel paste standardized labels.

(2) Shipping Company Refusal to Load: How to Improve Declaration Approval Rate

Some shipping companies have restrictions on carrying high-risk dangerous goods (such as Class 1 explosives and Class 6 highly toxic substances) or reduce the supply of dangerous goods cabins during peak seasons (e.g., Christmas stock-up period), resulting in declaration rejection after submission. Enterprises can take the following measures:

• Book cabins 1-2 months in advance to reserve sufficient review time;
• Choose professional dangerous goods shipping companies (such as Maersk and COSCO Shipping Dangerous Goods Special Line), which have richer experience in dangerous goods transportation and more cabin resources;
• Provide additional safety certificates (such as cargo stability test reports and emergency response plans) to reduce the shipping company’s risk concerns.

III. MSDS Documents: The “Identity Certificate” and “Customs Clearance Key” for Chemicals

The Material Safety Data Sheet (MSDS) is a comprehensive document describing the physical and chemical properties, hazardous characteristics, safe operation methods, and emergency measures of chemicals. It also serves as the core basis for chemical sea freight customs clearance, port inspection, and cargo receipt. Whether for shipping company booking, customs clearance, or consignee acceptance, a complete and accurate MSDS document is required, and the standardization of its content directly affects the smoothness of the sea freight process.

1. Core Content and International Standards of MSDS Documents

(1) 16 Standard Items of MSDS (Compliant with ISO 11014 Standard)

A formal MSDS document must include 16 chapters, all of which are indispensable. The content closely related to sea freight includes:

• Chapter 1: Identification of the Substance or Mixture: Clearly state the cargo name, CAS number, UN number, and hazard category (e.g., “Ethanol, CAS 64-17-5, UN1170, Class 3 Flammable Liquid”);
• Chapter 2: Hazards Identification: Explain the main hazardous properties of the cargo (e.g., “Flammable; its vapor can form an explosive mixture with air, which can cause combustion and explosion when exposed to open flames or high heat”);
• Chapter 4: First-Aid Measures: Specify emergency treatment methods for scenarios such as skin contact, eye contact, and inhalation (e.g., “Skin Contact: Immediately remove contaminated clothing and rinse thoroughly with plenty of running water for at least 15 minutes”);
• Chapter 5: Fire-Fighting Measures: Clarify applicable fire-extinguishing agents (e.g., “For ethanol fires, alcohol-resistant foam, dry powder, or carbon dioxide can be used”) and fire-fighting precautions;
• Chapter 14: Transport Information: Include the IMDG Code hazard category, packaging grade, UN number, and transport taboos (e.g., “Keep away from ignition sources and heat during transportation; mixing with oxidizers is strictly prohibited”);

This content must be compiled by professional institutions (such as chemical research institutes and third-party testing companies) to ensure compliance with international standards and target country requirements.

(2) Common Issue: “Invalid” MSDS Documents

Some enterprises use MSDS documents with incomplete content or incorrect information, leading to customs clearance delays, such as:

• Missing Chapter 14 “Transport Information,” making the shipping company unable to confirm the cargo’s hazardous properties and refuse booking;
• Mismatched hazard categories and UN numbers (e.g., mistakenly writing UN1830 for sulfuric acid as UN1825), which is deemed false declaration during customs review;
• Non-compliant language (e.g., only providing a Chinese version of MSDS for exports to the EU, without an English or local language version);

Such “invalid” MSDS documents need to be re-compiled, taking an average of 7-10 days, which may cause the cargo to miss the scheduled shipment and incur demurrage fees ($100-200/container/day) and storage fees.

2. Application Scenarios and Modification Requirements of MSDS Documents

(1) MSDS Application in the Full Sea Freight Process

MSDS documents are required in multiple links of chemical sea freight:

• Booking Link: The shipping company uses the MSDS to confirm whether the cargo meets the carrying requirements, such as whether special cabins (e.g., refrigerated cabins, ventilated cabins) are needed;
• Port Inspection Link: Customs or maritime departments use the MSDS to verify whether the cargo’s hazardous properties are consistent with the declaration information;
• Destination Port Customs Clearance Link: The consignee must submit the MSDS to the local customs to prove that the cargo meets the importing country’s safety and environmental protection standards (e.g., the EU REACH Regulation requires the MSDS to include substance concentration and registration information);
• Emergency Link During Transportation: In case of accidents such as cargo leakage or fire, the crew can quickly obtain emergency treatment methods through the MSDS to reduce accident losses.

(2) Modification and Update of MSDS Documents

When the composition, concentration, or packaging of chemicals changes, the MSDS document must be modified and re-reviewed accordingly, such as:

• Increasing the proportion of flammable solvents in coating products (lowering the closed-cup flash point from 55°C to 45°C) requires updating Chapter 2 “Hazards Identification” and Chapter 14 “Transport Information” to re-determine the hazard category;
• Changing the packaging from 20L plastic barrels to 1000L IBC containers requires updating the packaging grade and carrying requirements in Chapter 14 “Transport Information”;

If enterprises fail to update the MSDS in a timely manner, the document information may not match the actual cargo, leading to detention during destination port customs clearance (e.g., the average processing time for cargo detained by US Customs due to incorrect MSDS information is 15-20 days).

IV. Chemical Access Policies of Different Countries: The “Final Threshold” for Sea Freight

The ultimate success of chemical sea freight depends not only on compliant declaration and complete documents but also on meeting the access policies of the destination country. Based on considerations of safety, environmental protection, and public health, different countries have formulated strict chemical import regulations—such as the EU’s REACH, the US’s TSCA, China’s GB Standards, and Japan’s MITI Certification. Enterprises must understand and meet these requirements in advance; otherwise, they will face risks such as failure to clear customs or even cargo destruction.

1. EU: REACH Regulation and CLP Labeling Requirements

(1) REACH Regulation: Registration, Evaluation, Authorization, and Restriction of Chemicals

REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) is the core EU regulation for chemicals. It requires all chemicals imported into the EU (whether pure substances or mixtures) to meet the following requirements:

• Registration: Chemicals with a substance concentration ≥ 0.1% and an annual import volume ≥ 1 ton must be registered with the European Chemicals Agency (ECHA) and submit a Chemical Safety Report (CSR);
• Authorization: Chemicals classified as “Substances of Very High Concern” (SVHC) (e.g., asbestos, phthalates) can only be imported after obtaining authorization (the authorization process takes an average of 6-12 months and costs over €50,000);
• Restriction: The use and import of some hazardous substances (e.g., certain heavy metals, flame retardants) are strictly restricted, such as a lead content limit of no more than 0.1%;

For example, if a Chinese enterprise exports coatings to the EU and the coatings contain SVHC substances (e.g., DEHP, di(2-ethylhexyl) phthalate) with a concentration ≥ 0.1%, REACH registration must be completed first; otherwise, the cargo will be refused entry at EU ports.

(2) CLP Labeling: Unified Hazard Communication Requirements

In addition to the REACH Regulation, the EU also requires chemical packaging to be labeled in accordance with the Regulation on the Classification, Labeling and Packaging of Substances and Mixtures (CLP). The label must include:

• Hazard symbols (e.g., flame symbol for flammable liquids, corrosion symbol for corrosive substances);
• Hazard statements (e.g., “Highly flammable liquid and vapor,” “Causes severe skin burns and eye damage”);
• Precautionary statements (e.g., “Keep away from heat, sparks, open flames, and hot surfaces,” “Wear protective gloves and eye protection”);

The CLP label must use the language of the EU member state (e.g., German for Germany, French for France). If the label is non-standard, the cargo cannot circulate within the EU, and the enterprise must re-label it (with an average cost of $0.5-1 per piece).

2. US: TSCA Certification and EPA Registration

(1) TSCA Certification: Toxic Substances Control Act

The US Toxic Substances Control Act (TSCA) requires all chemicals imported into the US (including pure substances, mixtures, and chemical substances in products) to meet the following requirements:

• Premanufacture Notice (PMN): If a chemical is a “new chemical substance” not listed in the TSCA, a PMN application must be submitted to the US Environmental Protection Agency (EPA) 90 days before import to prove that the substance poses no risks to human health and the environment;
• Existing Chemical Substance Declaration: If a chemical is an “existing chemical substance” listed in the TSCA, an Inventory Reporting must be submitted to confirm the substance’s registration information in the TSCA Inventory;
• Restricted Substances: The TSCA prohibits the import of certain hazardous chemical substances (e.g., polychlorinated biphenyls, PCBs) and restricts the use of some substances (e.g., formaldehyde emission limit of no more than 0.1ppm);

For example, if a Chinese enterprise exports plastic additives to the US and the additive is a new chemical substance not listed in the TSCA, a PMN application must be submitted 90 days in advance; otherwise, the cargo will be detained by US Customs (with an average detention time of 20-30 days).

(2) EPA Registration: Additional Requirements for Specific Chemicals

For chemicals with specific uses (e.g., pesticides, disinfectants, fuels), the US also requires registration with the EPA (Environmental Protection Agency):

• Pesticide Chemicals: Must go through the EPA pesticide registration process and submit toxicity test reports and environmental impact assessment reports (the registration cost exceeds $100,000 and takes 1-2 years);
• Disinfectant Chemicals: Must obtain EPA Antimicrobial Product Registration (EPA Registration Number) to prove that the product has effective bactericidal effects and is safe for humans;

If an enterprise fails to complete EPA registration, even if it passes TSCA certification, the cargo cannot be sold in the US (e.g., the detention rate of unregistered disinfectants by US Customs exceeds 80%).

3. China: GB Standards and Customs Inspection and Quarantine

(1) GB National Standards