Inspection requirements for limited quantity packaging of hazardous chemicals shipped by sea

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On December 18, 2020, the General Administration of Customs issued the "Announcement on Issues Concerning the Inspection and Supervision of the Import and Export of Hazardous Chemicals and Their Packaging" (General Administration of Customs Announcement No. 129, 2020). This announcement will be implemented from January 10, 2021, and the original General Administration of Quality Supervision, Inspection and Quarantine Announcement No. 30 of 2012 will be abolished at the same time.

The second point of Article 3 of the announcement stipulates: The shipper or his agent exporting hazardous chemicals must provide the "Outbound Goods Transport Packaging Performance Inspection Result Sheet" when reporting to the customs for inspection (bulk products and those exempted from the use of dangerous goods packaging by international regulations) except).

Let’s take a look at the new announcement’s inspection requirements for the most commonly used limited quantity packaging of dangerous goods for export by sea, which is exempted from international regulations.

01 Legal and regulatory basis

Chapter 3.4 of the "International Maritime Transport of Dangerous Goods" clarifies that a limited number of dangerous goods must be packaged in limited quantities and comply with the provisions of that chapter, except for the 7 situations listed (which do not have the test requirements for relevant packaging testing in 4.1.1.3) , any other provisions of these rules shall not apply.

For this reason, if an enterprise uses a limited quantity of packaging when exporting hazardous chemicals by sea, it does not need to provide the "Outbound Goods Transport Packaging Performance Inspection Result Sheet".

02 Limited quantity packaging regulations

Intuitively speaking, the use of limited quantity packaging for dangerous goods means that when transporting a certain dangerous goods, in terms of packaging, many small barrels and bottles are used instead of large packages, and then these small packages are placed in a strong outer package, and the outer package is Add absorbent materials to reduce potential hazards or dangers, as shown in the figure below:

Packages containing limited quantities of dangerous goods no longer need to display the flammable, corrosive, oxidizing and other shipping labels, marine pollutant markings, correct shipping names and UN numbers of the goods contained, but they need to display the limited quantity packages in the figure below. piece mark. As shown in the picture:

The upper and lower parts and edges of the mark on a limited number of packages should be black, and the middle area should be white or an appropriate contrasting color. The minimum size of the mark: 100mm*100mm, the minimum width of the diamond edge: 2mm; if the size of the package requires, the size can be reduced , but not smaller than 50mm*50mm, and the mark should still be clearly visible.

Package weight

For example, the recently common alcohol spray, UN number 1170, is suitable for Class III packaging in a limited quantity of 5L. That is to say, the maximum volume of each small package cannot exceed 5L. If the small package is fragile or breakable, such as an inner package made of glass, porcelain, stoneware or some plastics, it needs to be placed in an intermediate package that meets certain requirements and then placed in the outer package. The total gross weight of the package should not exceed 20 kg. If the inner packaging is not fragile or breakable, there is no need to use intermediate packaging, and the total gross weight of the packages should not exceed 30 kg.

Notice! Limited quantities do not apply to all dangerous goods.

03 Limited quantity packaging inspection content

Customs packaging of hazardous chemicals exported in limited quantities shall be in accordance with Chapter 3.4 of the "International Maritime Transport of Dangerous Goods Regulations" as well as the "Limited Quantity and Packaging Requirements for Dangerous Goods" (GB 28644.2-2012) and the "Inspection Regulations for Limited Quantity Packaging of Exported Dangerous Goods" (SN/T 4149-2015) and other requirements for inspection.

04 Things to note when reporting

1. How to fill in the "Packaging Category"? If you use limited quantity packaging, you can select "None".

2. How to fill in the "Packaging UN Mark"? If limited quantity packaging is used, "/" can be filled in.