The customs clearance process of dangerous goods involves strict compliance requirements and multi-link supervision. The following is a full process analysis and key points:
I. Preliminary preparation stage
- MSDS file (Material Safety Data Sheet)
Function: MSDS is the core document for customs clearance of dangerous goods, containing information such as chemical composition, physical properties, hazards, and safe operation instructions.
Compliance points:
Must be issued by the manufacturer or professional organization and comply with the standards of the target country (such as China GB/T 16483, US OSHA 29 CFR 1910.1200, EU REACH regulations).
16 standard contents must be included (such as first aid measures, fire fighting measures, leakage handling, etc.).
Language requirements: Usually bilingual versions in Chinese and English are required (Chinese version may be mandatory for customs clearance in China).
- Classification of hazardous properties and UN number
Classification basis: According to the United Nations Recommendations on the Transport of Dangerous Goods (TDG) or the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
UN number: Each dangerous good corresponds to a unique UN number (such as UN1263 for paint), which must be clearly marked in the transportation document (such as sea/air waybill).
- Packaging and labeling
Packaging standards: Packaging that meets UN specifications (passes drop, stacking, etc. tests) and is marked with UN marks (such as UN4G/X/1.4/2025).
Labels and signs: Paste GHS hazard pictograms and transport labels (such as explosives, flammable liquids, etc.), and hang dangerous goods signs on the outside of the container.
II. Transportation and declaration stage
- Choice of transportation mode
Sea transportation: Must comply with the International Maritime Dangerous Goods Code (IMDG Code).
Air transportation: Must comply with the International Air Transport Dangerous Goods Regulations (IATA DGR).
Land transportation: must comply with the Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) or China’s Regulations on the Administration of the Transport of Dangerous Goods by Road.
- Preparation of transportation documents
Dangerous Goods Declaration (DGD): filled in by the shipper and reviewed by the carrier.
Packing certificate: proves that the packaging of dangerous goods meets the requirements (required for sea transportation).
Special documents: such as lithium batteries, UN38.3 test report and 1.2-meter drop test report are required.
III. Customs clearance declaration stage
- Customs declaration documents
Basic documents: contract, invoice, packing list, bill of lading.
Special documents:
“Identification Result Sheet for the Use of Dangerous Goods Transport Packaging for Entry and Exit” (Chinese imports require customs or commodity inspection agencies to issue).
“Declaration of Conformity of Imported Dangerous Chemicals Business Enterprises” (required by China).
License documents: such as “Registration Certificate for Imported Dangerous Chemicals” (some countries require advance registration).
- Key points of customs declaration
HS code classification: accurately declare the HS code corresponding to the dangerous goods (such as 2828.10.00 for liquid chlorine).
Declaration elements: indicate the hazard category, UN number, and packaging level (such as PG II).
Electronic declaration: Some countries need to submit through a dedicated system for dangerous goods (such as China’s “single window” dangerous goods module).
IV. Inspection and supervision
- On-site inspection
Unpacking inspection: Customs or maritime departments may check the consistency of packaging, labels, and documents.
Sampling test: If the chemical composition does not match the declaration, it may be sent to the laboratory for testing.
- Special supervision requirements
Isolated storage: Dangerous goods must be stored in a dangerous goods warehouse designated by the customs.
Port restrictions: Some dangerous goods are only imported at specific ports (such as Shanghai Yangshan Port, Tianjin Port, etc.).
Environmental protection requirements: Goods containing persistent organic pollutants (POPs) must provide a “New Chemical Environmental Management Registration Certificate”.
V. Release and subsequent management
- Release conditions
After the documents are complete and the inspection is qualified, the customs will issue the “Entry Goods Clearance Certificate”.
Some dangerous goods need to be inspected at the destination (such as highly toxic chemicals).
- Subsequent compliance
Warehousing and transportation: must be operated by logistics companies with dangerous goods qualifications.
Emergency plan: The company needs to file emergency plans for dangerous goods leakage, fire, etc.
VI. Common risks and responses
Incomplete documents: Missing MSDS or incorrect UN number may lead to return.
Solution: Entrust a professional organization to review the documents in advance.
Unqualified packaging: Non-UN packaging or label detachment will result in cargo detention.
Solution: Choose a qualified dangerous goods packaging supplier.
Policy changes: For example, China will implement stricter transportation restrictions on lithium batteries in 2023.
Solution: Pay attention to the annual updates of the General Administration of Customs or IMO/IATA.