Belgium: A Testing Ground for EU Regulations – Chemical and Weight Declarations for Exporting Specialty Steel to Antwerp

As the location of the EU headquarters and Europe’s second-largest port, Belgium is not only a logistics hub but also a testing ground for new EU regulations. The Port of Antwerp is renowned for its specialized chemical and steel handling capabilities, meaning that exporting specialty steel there will face the EU’s most stringent and cutting-edge chemical and weight declaration requirements. Precise compliance is the only passport to this high-end market.

Part One: Chemical Regulation of Specialty Steel – From REACH to CLP: Precise Compliance

1. Core Regulatory Framework and Antwerp’s Unique Enforcement

Belgian customs and federal public service agencies are known for their rigorous enforcement of EU chemical regulations.

Regulatory System Core Requirements Impact on Specialty Steel Antwerp Practice Characteristics

REACH (Registration, Assessment, Authorization and Restriction) Controls substances themselves, preparations, and substances in articles. 1. Alloying elements: Whether the content of nickel, chromium, molybdenum, vanadium, etc., exceeds the concentration threshold for substances in articles (usually 0.1% w/w).

2. Surface Treatment Substances: Restricted substances (such as SVHCs) in plating (e.g., zinc, tin) and coatings (e.g., paint, plastics). Customs often requires importers to provide a Supply Chain Information Transmission Form to prove compliance with REACH notification obligations. High-alloy products such as stainless steel and tool steel are subject to focused inspection.

CLP (Classification, Labelling, and Packaging): Standardized classification, labeling, and packaging of hazardous chemicals and mixtures. 1. Hazard Classification: Certain metal powders (e.g., aluminum-magnesium alloy powder) and residues from pickling or passivation treatments may be classified as hazardous materials.

2. Packaging Labeling: If classified as hazardous, packaging must comply with CLP labeling regulations, even if the steel itself is not hazardous. Port authorities conduct rigorous visual inspections of hazardous material markings on cargo packaging; non-compliance will result in operational suspension.

POPs (Persistent Organic Pollutants) Regulations: Prohibition or restriction of certain persistent organic pollutants. Attention is paid to whether steel anti-corrosion oils and coatings contain restricted substances such as short-chain chlorinated paraffins. The Port of Antwerp possesses advanced chemical screening laboratories capable of rapid testing of suspected goods.

2. Key Documents and Data for Special Steel Chemical Declarations

Material Data Sheet:

A complete chemical composition report, accurate to all alloying elements and trace residual elements, must be provided.

A declaration must be made regarding whether the product has undergone pickling, passivation, oiling, or other treatments, specifying the type of treatment agent.

Safety Data Sheet:

If the steel is classified as hazardous by the CLP due to subsequent processing (e.g., powder, machining waste) or surface treatment, an SDS conforming to EU format must be provided with the shipment.

Declaration of Conformity:

For REACH regulations, particularly the SVHC list, a declaration document must be provided proving that the SVHC content in the product does not exceed 0.1%, or that notification has been made.

Best Practice: Provide an SVHC screening test report issued by a third-party laboratory; this is the most widely accepted proof by Belgian Customs.

Part Two: Weight Declaration at the Port of Antwerp – Precise Implementation and Error Control of VGM

1. Belgium’s Unique and Rigorous Interpretation of SOLAS VGM

According to the International Maritime Organization’s Convention on the Safety of Life at Sea (COMAN Maritime Convention) requirements for container gross weight verification, Belgium’s standards are higher than the global average.

Weighing Method Selection:

Method 1 (Weighing the Gross Container Weight): Highly regarded in Antwerp. The port recognizes data from its official weighing station network, with extremely low error tolerance.

Method 2 (Calculating the Sum of All Contents): Acceptable, but requires that all weighing equipment for all weight components be calibrated by a nationally or EU-approved authority, and accompanied by a copy of the calibration certificate.

Declaration Deadline and Format:

Deadline: Must be submitted to the shipping company and the Antwerp Port Authority via the Electronic Data Interchange System 24 hours before container loading.

Mandatory Format: Must use standard data fields including carrier, vessel, voyage number, container number, weighing method, verifier, and date.

Error Tolerance and Penalties:

Permissible Error: Typically ±5% (but in practice, the Port of Antwerp tends to be stricter at ±2-3%).

Consequences of Exceeding Tolerance: Re-weighing (cost borne by the shipper); if the error is too large (>5%), fines, delayed loading, and record-keeping may result, increasing future inspection frequency.

2. Special Challenges and Solutions for VGM Declaration of Special Steel

Challenge 1: Moisture Absorption/Volatilization:

Precision packaging of special steel (e.g., using rust-proof paper, desiccants) may experience slight weight changes due to variations in ambient humidity.

Solution: Packaging and weighing should be conducted in a temperature and humidity controlled environment; the environmental conditions at the time of weighing should be noted in the VGM declaration.

Challenge 2: Weight of Binding and Reinforcing Materials:

The weight of supports, timber, steel cables, etc., used to secure large special steel components is considerable and easily overlooked.

Solution: Develop a “Standard Weight Table for Binding Materials,” review and update it after each use, and input it as fixed data into the calculation system.

Challenge 3: Calibration Traceability:

Belgian Customs may trace the calibration records of weighing equipment.

Solution: Establish a strict calibration management ledger for all weighbridges, crane scales, etc., used for Method 2 weighing, ensuring they are within their validity period and comply with ISO standards.

Part Three: Integrated Declaration and Antwerp Digital Portal

1. Antwerp Port Single Window: APA / Port Community System All customs and port declarations must be made through the Antwerp Port Community System or its connected Belgian Customs Single Window.

Pre-declaration Integration:

Cargo Declaration: Submit a complete electronic manifest in advance, including chemical data (HS code linked to REACH/CLP information) and VGM data.

Risk Screening: The system automatically cross-references declaration data with the regulatory database, triggering green (release), orange (document check), or red (physical inspection) channel instructions.

Digital Document Flow:

All supporting documents (SDS, Declaration of Conformity, Weighing Report) should be uploaded to the system in advance and linked to the specific container number and bill of lading number.

Use standardized codes (such as UN numbers and CAS numbers) to declare chemical information to avoid misunderstandings caused by free text descriptions.

2. Fast Track Application for Specialty Steels

The Value of AEO Certification: Exporters holding EU Authorized Operator certification can enjoy lower inspection rates and simplified declaration procedures in Antwerp.

Long-Term Cooperation Plan: Establish long-term cooperation with professional steel freight forwarders or customs brokers recognized by the Port of Antwerp. They are familiar with the port’s regulatory focus on specialty steels, can anticipate risks, and optimize declaration strategies.

Pre-Ruling Application: For new or complex specialty steels, a binding pre-ruling can be applied for in advance from Belgian customs to clarify its HS code, country of origin, and applicable regulatory requirements, ensuring certainty in customs clearance.

Part Four: Compliance Risk Mitigation and Strategic Recommendations

1. Establish an Internal Checklist for “Belgian Special Regulations”

Chemical Checkpoints:

Have all alloying elements and surface treatment substances been compared with the latest SVHC list and restricted list?

Are the SDS and Declaration of Conformity in Dutch, French, or German (an official Belgian language)?

Weight Checkpoints:

Is the last calibration date of the VGM weighing equipment still valid?

Does the declared weight include all permanent fixtures?

2. Division of Responsibilities with the Belgian Importer
   Clearly define in the commercial contract:

Information Provision Obligation: The exporter is responsible for providing chemical safety information and test reports that comply with EU/Belgian regulations.

Declaration Responsibility: Clearly define which party (exporter or importer) is responsible for the final customs and port declaration in Antwerp, and the associated costs.

Liability Exemption: The exporter is not liable for delays caused by the importer’s failure to provide necessary information or complete its responsible declaration procedures in a timely manner.

Conclusion: Establishing the Gold Standard in the EU’s “Regulatory Laboratory”
Exporting specialty steel to Antwerp, Belgium, is a “stress test” conducted under the EU’s most stringent regulatory environment. Successfully passing this test means:

Obtaining the highest level of compliance certification: Meeting Belgian requirements, i.e., meeting the strictest EU standards, removes the biggest regulatory hurdle for entering other EU markets.

Forging refined management capabilities: From milligram-level chemical management to kilogram-level weight control, this process will force companies to establish an unparalleled precision supply chain management system.

Winning the trust of the high-end market: The ability to continuously and stably supply Antwerp is itself the strongest endorsement of product quality, compliance capabilities, and supply chain reliability.

Therefore, dealing with Antwerp’s chemical and weight declarations should not be seen as a cumbersome cost center, but rather as a strategic investment to hone the company’s core competitiveness in the European market. The “zero-defect” compliance process established here will become the gold standard for the company’s success throughout the EU market.