China to Pilot Nationwide "Batch Inspection" Reform for Exported Hazardous Chemicals and Dangerous Goods Packaging

On July 8, 2024, the Inspection and Quarantine Department of the General Administration of Customs jointly issued a notice announcing the nationwide pilot of the "batch inspection" reform for the packaging of exported hazardous chemicals and dangerous goods.

This policy aims to further strengthen the supervision of exported hazardous chemicals, standardize inspection models, and enhance the safety and regulatory efficiency of exported goods.

This became effective from the date of the announcement

What is the scope of "batch inspection"?

1. Exported hazardous chemicals listed in the latest edition of the "Catalogue of Hazardous Chemicals."
2. Exported dangerous goods and their packaging listed in the "United Nations Recommendations on the Transport of Dangerous Goods" (except for Class 6.2 infectious substances and Class 7 radioactive materials).

What is the "batch inspection" model?

The "batch inspection" model, while maintaining the principle of "inspection per batch," selects high-quality enterprises as pilot subjects and optimizes the adjusted model.

The definition of the same batch varies slightly in the inspection of exported hazardous chemicals, the identification of the use of exported dangerous goods packaging, and the performance identification of exported dangerous goods packaging, is now classified as follows:

1. Definition of the same batch under the inspection of exported hazardous chemicals (must meet all the following requirements):

1. Same manufacturer;
2. Same process; and
3. Same components/composition, same hazardous characteristics.

2. Definition of the same batch under the identification of the use of exported dangerous goods packaging (must meet all the following requirements):

1. Same manufacturer;
2. Same mode of transport (including the same specifications and markings on the packaging); and
3. Same type, components, and content.

Note: Paints that are dangerous goods that differ only in color but have consistent dangerous characteristics can be considered as one batch.

3. Definition of the same batch under the performance identification of exported dangerous goods packaging (must meet all the following requirements):

1. Same manufacturer;
2. Same design type; and
3. Same materials, process.

How will "batch inspections" be implemented?

For the inspection of exported hazardous chemicals, the identification of the use of packaging for exported dangerous goods, and the performance appraisal of packaging for exported dangerous goods, the implementation of 'batch inspection' varies slightly. The categories are as follows:

1. For the same 'batch inspection' of exported hazardous chemicals: Customs conducts on-site inspections and sampling inspections when enterprises first declare exports. Once the inspection is passed, within the 'batch inspection' cycle, Customs may verify subsequent declarations of the same batch of products by reviewing relevant documents, without conducting further on-site inspections.
2. For the same 'batch inspection' of the identification of the use of packaging for exported dangerous goods: After an on-site real goods identification by Customs, the enterprise can export in several declared batches within the validity period of the identification documents. Customs issues a split certificate based on the use identification document, and no further on-site identification is conducted.
3. For the same 'batch inspection' of the performance appraisal of packaging for exported dangerous goods: Customs can issue multiple performance inspection result certificates based on a valid dangerous goods packaging performance test report, a self-test report provided by the dangerous goods packaging manufacturer, and a quality assurance, without conducting further testing.

CIRS Insights

Currently, the 'batch inspection' for exported hazardous chemicals and dangerous goods packaging is carried out among pilot enterprises, which are generally customs advanced certified enterprises and non-distrusted enterprises that have passed the risk assessment of various directly subordinate customs. The 'batch inspection' process includes an on-site inspection during the first export, and within the batch inspection cycle, customs will verify by reviewing relevant documents to reduce on-site inspections. 'Batch inspection' not only improves inspection efficiency but also reduces the burden on enterprises. Additionally, regarding the 'batch inspection' cycle, officials have not yet provided a detailed scope, and different customs districts may make comprehensive judgments based on actual supervision conditions.

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Further Information

General Administration of Customs Notice