The “Difficulty in Exporting” Fire Extinguishers: An Analysis of Constraints on China’s Cross-Border Fire Extinguisher Trade

As a major global producer of fire-fighting equipment, China has long ranked among the top in the world in terms of fire extinguisher exports. However, enterprises often face the dilemma of “high compliance costs, complex procedures, and numerous barriers” in practical operations. This “seemingly restricted” situation does not stem from a single export ban, but rather a “multi-layered constraint network” formed by the hazardous goods nature of fire extinguishers, international technical barriers, export control regulations, and logistics compliance requirements.

I. Hazardous Goods Nature: Rigid Safety Thresholds in Transportation

The core function of fire extinguishers relies on compressed or liquefied gas to drive the release of fire-extinguishing agents. This characteristic directly classifies them into the international hazardous goods regulatory system, making them a fundamental compliance obstacle in the export process.

(1) Mandatory Constraints from International Transportation Classification

According to the International Maritime Dangerous Goods (IMDG) Code, most fire extinguishers are explicitly categorized as Class 2.2 Non-Flammable, Non-Toxic Gases with a unified United Nations (UN) number of UN 1044. This classification implies:

• Whether transported by air, sea, or land, dedicated transportation norms for hazardous goods must be followed, including the use of carriers with hazardous goods transportation qualifications and the deployment of professional escorts;
• Packaging must pass pressure tightness testing. Even large fire extinguishers transported without outer packaging require approval from the competent authority and protection for key components such as valves;
• Additional “Dangerous Goods Transport Declarations” must be submitted with transportation documents, detailing information such as cargo categories and emergency response measures. Any omissions may result in customs detention of the goods.

(2) Pre-Approval Requirements for Domestic Logistics

China implements “full-chain supervision” over the export of hazardous goods. Enterprises must complete multiple approvals before goods leave the country:

• Apply to the local emergency management department for a Hazardous Chemicals Safety Use Permit (required for some fire extinguishers containing special fire-extinguishing agents);
• Entrust a qualified institution to conduct hazardous goods packaging performance testing and obtain a Result Certificate for the Inspection of Export Dangerous Goods Transport Packaging Use;
• For sea freight exports, a Shipborne Dangerous Goods Declaration Form must also be filed with maritime authorities. Undeclared goods are deemed “smuggled hazardous goods,” subject to confiscation and heavy fines (e.g., Yingkou Maritime Safety Administration once investigated a violation case where fire extinguishers were falsely declared as “auto parts”).

II. Technical Trade Barriers: Import Country Standard Access Barriers

Different countries have differentiated requirements for the safety performance, testing methods, and certification procedures of fire extinguishers, forming a “one country, one standard” access pattern. Chinese enterprises must meet the specific standards of importing countries to enter their markets.

(1) Strict Certification Systems in Developed Countries

Markets in Europe, the United States, Japan, and South Korea generally have mandatory certification systems, and products failing to obtain certification are prohibited from circulation:

• European Union (EU): Fire extinguishers must comply with the “Pressure Equipment Directive (PED)” and “Construction Products Regulation (CPR)” under CE certification. This not only requires products to pass tests such as burst pressure and tightness but also mandates enterprises to establish comprehensive quality control systems;
• United States (U.S.): Compliance with standards set by the National Fire Protection Association (NFPA) (e.g., NFPA 10 Standard for Portable Fire Extinguishers) is mandatory, along with certification from testing bodies such as Underwriters Laboratories (UL) or Factory Mutual Research Corporation (FM);
• Japan: Testing by the “Fire Equipment Inspection Association” designated under Japan’s Fire Service Act is required to obtain a Fire Equipment Inspection Certificate. Japan also imposes higher requirements than international standards on the discharge time and fire-extinguishing efficiency of fire extinguishers.

(2) Standard Differentiation Challenges in Developing Countries

Even in developing countries with relatively lower access thresholds, standard differences can still become export obstacles. For example, Egypt has issued the ES 734 standard for portable dry powder fire extinguishers, which clearly specifies design requirements, pressure testing methods, and conformity assessment procedures for 1-12kg fire extinguishers. It also mandates that all testing be conducted in laboratories accredited in Egypt. Chinese enterprises that fail to adapt to such regional standards in advance may face the risk of customs clearance failure upon cargo arrival.

(3) Environmental and Material Restrictions

Some countries impose environmental controls on the fire-extinguishing agent components of fire extinguishers:

• The EU, Canada, and other regions have fully banned the import of fire extinguishers containing chlorofluorocarbons (CFCs). Some outdated models still used in China need to be upgraded to environmentally friendly fire-extinguishing agents;
• California (U.S.) sets upper limits on the phosphate content in dry powder fire extinguishers and requires enterprises to provide component testing reports. Products exceeding the limit are classified as “environmental pollutants.”

III. Export Control Regulations: Dual-Use Items and Country-Specific Restrictions

Although fire extinguishers themselves are not typical “dual-use items” (items with both civilian and military applications), they may trigger China’s export control measures in specific scenarios or be subject to national security reviews by importing countries.

(1) Associated Control Risks for Dual-Use Items

According to the Regulations of the People’s Republic of China on the Export Control of Dual-Use Items, if key components of fire extinguishers (such as pressure vessels and valves) can be modified for military equipment (e.g., small propulsion devices), or if the export destination is a “high-risk country or region,” enterprises must apply to the Ministry of Commerce for an export license:

• For exports to UN-sanctioned countries (e.g., Iran, North Korea), even if fire extinguishers are for civilian use, “End-User and End-Use Certification Documents” must be submitted to prove that the goods will not be diverted for military purposes;
• Enterprises listed on the “control list” due to illegal exports are prohibited from applying for export licenses for 5 years, and applications from their associated enterprises will be subject to enhanced scrutiny.

(2) National Security Reviews by Importing Countries

Some countries classify fire-fighting equipment as “critical infrastructure supplies” and impose additional reviews:

• The U.S. conducts “supply chain security reviews” on fire extinguishers imported from China, requiring enterprises to provide proof of raw material sources to prevent “maliciously modified pressure vessels” from entering the country;
• Countries such as India and Brazil stipulate that fire extinguishers for government procurement projects must prioritize locally produced products. Imported products require 6-12 months of qualification review.

IV. Insufficient Enterprise Compliance Capabilities: Common Internal Causes of Export Failures

In addition to external constraints, the weak compliance awareness and operational capabilities of small and medium-sized Chinese enterprises are also important reasons for “export difficulties”:

(1) Inadequate Preparation for Certification and Testing

Many enterprises fail to research the standards of importing countries in advance and engage in blind production, resulting in non-compliant products. For example, a company exporting carbon dioxide fire extinguishers to Europe had its goods returned by customs for failing the PED Directive’s low-temperature impact test (tightness testing at -20°C), causing direct losses exceeding 1 million yuan.

(2) Irregular Logistics Operations

To reduce costs, some enterprises entrust logistics companies without hazardous goods transportation qualifications or conceal the hazardous nature of the goods. In a 2024 case investigated by Yingkou Maritime Safety Administration, the shipper falsely declared fire extinguishers as “auto parts,” leading to container detention and a fine of three times the cargo value imposed on the enterprise.

(3) Lack of Document Management

Exports of hazardous goods require more than 10 supporting documents (e.g., inspection reports, permits, declaration forms). Some enterprises experience customs clearance delays due to incomplete or incorrectly filled documents. For instance, an enterprise exporting fire extinguishers to Southeast Asia had its goods detained at the port for 2 months due to the absence of a Result Certificate for the Inspection of Export Dangerous Goods Transport Packaging Use, incurring high storage fees.

V. Key Paths for Compliant Exports

Despite numerous constraints, Chinese enterprises can overcome barriers through the following measures:

1. Proactive Standard Adaptation: Conduct testing through third-party institutions such as SGS and TÜV before export to obtain mandatory certifications from importing countries (e.g., CE, UL, ES 734);
2. Compliant Logistics Management: Collaborate with enterprises with hazardous goods transportation qualifications (e.g., Sinotrans Dangerous Goods Logistics) and strictly follow the IMDG Code for packaging and declaration;
3. Control Risk Screening: Query the risk level of the destination through the Ministry of Commerce’s “Dual-Use Items Export Control Information Service Platform” and complete licensing procedures in advance;
4. Supply Chain Transparency: Retain raw material procurement vouchers and production testing records to respond to supply chain reviews by importing countries.