China-Do products exempt from using hazardous materials packaging under international regulations need to be declared as dangerous goods during import customs clearance? | regulatory trends

Specific Q: Our company imports a product named "Aziridine," which is classified as a hazardous material with the United Nations number UN3082, and falls under Hazardous Goods Category 9. However, it is exempt from hazardous materials packaging under international regulations, as each package contains 5kg in a plastic can. Should this product be declared as hazardous goods during import customs clearance?

A: According to the requirements of the "Announcement on Issues Concerning the Inspection and Supervision of Imported and Exported Hazardous Chemicals and the Packaging Thereof" (Customs Administration Announcement No. 129 of 2020), customs conducts inspections on hazardous chemicals listed in the national "Catalogue of Hazardous Chemicals" (latest edition). The consignor or their agent must accurately declare the hazard class, packaging type (except for bulk), United Nations UN number, and UN packaging markings during customs declaration. Additionally, they must upload the "Conformity Statement for Imported Hazardous Chemical Enterprises," details of added inhibitors or stabilizers (if applicable), Chinese hazardous warning labels (except for bulk products), and a sample of the Chinese Safety Data Sheet. Before proceeding with customs clearance for imports, companies should confirm whether the related products are listed in the "Catalogue of Hazardous Chemicals (2015)".

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