customs brokerage, freight forwarding and truck transportation

Shipping Non-Regulated Chemical Goods From China

: Transport

Chinese Dangerous Goods Compliance and the Testing Certificate 2018-04-17

Note: The following does not apply to general cargo (dry cargo that does not exhibit any hazardous properties whatsoever such as apparel, furniture, printed matter, etc.).

When shipping chemical goods or substances and it is determined that they are fully regulated, the suppliers in those cases have to provide a transport document (shipper’s declaration for dangerous goods) bearing all of the particulars that aid in identifying their substances and mitigating the hazards that are posed by carrying them as cargo. These topics are addressed at greater length in the various dangerous goods regulations that are applicable by mode of transport.

Shipping merchandise that includes batteries, the batteries are generally not regulated if they are shipped in or packaged together with the goods they are intended to power.
Alkaline batteries or cells are not regulated at all.

Other types of batteries, sealed lead-acid or especially lithium metal and lithium ion batteries are regulated if they are shipped alone (in bulk), but not if they pass a series of tests and/or are sent in or along with the merchandise.

In China, for several years already, if the shipper wants to offer goods up for transport and infers that they include a substances that is not regulated under special circumstances (exempt or not regulated by virtue of a Special Provision [by sea] or Packing Instruction [by air]} they have to provide a safety testing certificate that is prepared by a lab that is licensed by the Government of China that certifies their status as non-regulated.
  • For FOB terms it is the supplier’s obligation to provide the safety testing certificate
  • The testing certificate is a requirement of the Chinese Government (this rule only applies ex-China)
  • There are two versions: one for marine and the other for air (if the shipper intends to ship by both modes they need both certificates)
  • The certificate is renewable annually and if valid only for the calendar year in which it was produced (so if a supplier has a 2018 certificate, it becomes null and void on Jan. 1, 2019)
  • It is the supplier’s responsibility to possess a valid certificate if they intend to export their non-regulated freight from China
Attached are examples of the testing certificate as well as a non-exclusive list of licensed testing firms that the shipper can obtain their certificate(s) from (provided by COSCO in China).

At the P/O stage, just as for any other licensing requirements from their origin, you should be confirming with the shipper that they either possess current certificates or are able to obtain them by the time of booking in order to be able to export their goods legally.

Following the 2015 catastrophic event in Tianjin, the Chinese authorities have been clamping down on dangerous goods haphazardly.

One thing that remains constant about their regulatory effort (that came into effect after Tianjin) is the application of the safety testing certificate that helps Chinese exporters demonstrate the compliance of their non-regulated freight to carriers.

For any questions on the Chinese safety testing certificate in particular or dangerous goods compliance in general please contact Ted Chazin, Milgram’s Compliance and Risk Management Consultant.

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