“Sunscreen spray export detained? Dangerous goods transportation certification and lightning protection guide”

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”.

  1. 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.

  1. 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

  1. 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.

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