Does obtaining the "Dangerous Chemicals Business License" satisfy all compliance requirements for importing Class VIII chemical products?Last month,a client in Zhejiang who produces epichlorohydrin failed to confirm the compatibility between the "UN Number" of the goods and their packaging.As a result,the goods were deemed by customs to be "packaged in violation of dangerous goods transportation regulations" upon arrival,and were detained for 12 days.Additionally,the company faced a 30,000 yuan administrative fine.This is not an isolated case.Among the Class VIII chemical product import cases I’ve encountered,60% of the problems stem from "seemingly unimportant details".

Compliance Illusion of Class 8 Chemical Imports: 3 Overlooked Underlying Logics

The eight categories of chemical products refer to "corrosive substances" in the "Classification and Numbering of Dangerous Goods" (GB 13690-2009),which are divided into three categories: acidic corrosives,alkaline corrosives,and other corrosives.When importing such products,companies often fall into a "compliance illusion": they think that obtaining basic documents is enough,but they ignore the "detailed requirements" in the regulations - these details are precisely the core points of customs inspection.

According to the "Measures for the Inspection and Supervision of Imported Hazardous Chemicals" (Decree No.236 of the General Administration of Customs),the import of eight categories of chemical products must meet the "three elements": a compliant MSDS,a GHS label,and matching UN packaging.However,many agents and enterprises have misunderstandings about these three requirements,which ultimately lead to customs clearance delays or fines.

Eight categories of chemical productsAgency Landing SOP: 4 Steps to Handle Compliant Clearance

Step 1: Confirm the classification of the goods and the regulatory requirements

Output:

Two key questions need to be clarified before import:

• IsthecargoclassifiedasaCategory8corrosivesubstance?Thisneedstobedeterminedbasedonthe"HazardClassification"intheMSDS(e.g."SkinCorrosion/SeriousEyeDamage")andinaccordancewithGB13690-2009.
• Whataretheimportsupervisionrequirements?Usethe"HSCodeSearch"functionontheofficialwebsiteoftheGeneralAdministrationofCustomsofChinatoconfirmthesupervisiondocumentscorrespondingtothegoods(forexample,"A"indicatestheneedforanimportgoodscustomsclearancedocument,and"S"indicatestheneedforadual-useitemlicense).

Key Reminder:If the goods belong to both "dangerous chemicals" and "dual-use items",two licenses must be obtained simultaneously.

Step 2: Prepare the core documents

Output:

The list of documents required for the import of eight categories of chemical products (all of which are indispensable):

• Basictradedocuments:contracts,invoices,billsoflading,packinglists;
• Compliancedocuments:the"ImportDangerousChemicalsBusinessLicense"(coveringthescopeofbusinessforthegoods),the"MSDS"(containingGHSelements),andphotosoftheGHSlabelsontheouterpackagingofthegoods;
• Packagingdocuments:"UNNumberandPackagingMatchingDeclaration"(whichrequiresthemanufacturer’sstampandstatesthattheUNnumberonthepackagingmatchestheUNnumberofthegoods).

Step 3: Pre-declaration and risk assessment

Output:

Commission the customs broker to conduct the "pre-declaration of imported dangerous chemicals" through the "China International Trade Single Window".After submitting the above-mentioned documents,the customs will complete the risk assessment within 1-3 working days:

• Iftheassessmentissuccessful,thecustomswillissuea"NoticeofPre-declarationApproval",andthegoodscanbearrangedtoarriveattheport;
• Iftheevaluationfails,theapplicantwillberequiredtoprovideadditionalmaterials(suchasthe"IngredientTestingReport"andthe"PackagingPerformanceTestResultsSheet").

Step 4: On-site Inspection and Release

Output:

After the goods arrive at the port,the customs will conduct on-site inspections,with a focus on the following checks:

• IstheGHSlabelontheouterpackagingofthegoodscompliantwithregulations?
• IstheUNnumberonthepackagingconsistentwiththedocuments?
• IsthecompositionofthegoodsconsistentwiththeMSDS?

After the inspection,the customs will issue an "Inspection and Quarantine Certificate for Imported Goods",and the consignee can use this certificate to go through the release formalities at the port customs.

The hidden traps of importing eight categories of chemical products: Tax and compliance risks of "ingredient proportion"

Many enterprises and agents overlook an "unspoken rule": the "ingredient ratio" of eight categories of chemical products can affect the classification of HS codes.For example,in a batch of "acidic corrosive products",if the proportion of active ingredients (such as sulfuric acid) exceeds 90%,the HS code will change from "38089300 (other corrosive products)" to "28070000 (sulfuric acid)",and the corresponding tariff rate will rise from 6% to 10%.Moreover,the regulatory requirements will also change (e.g.requiring an "Industrial Product Production License").

More dangerously,if the classification is incorrect,the customs will require you to pay "additional taxes and late payment penalties" upon inspection,and may even retroactively collect taxes for the past three years.My advice is:Hire a professional chemical classifier for "pre-classification" before importSubmit an application through the "Pre-Classification Service Platform" on the official website of the General Administration of Customs of China to avoid compliance issues caused by ingredient ratios.

3 things you can do this afternoon: Avoid the import risks of eight types of chemical products

• ChecktheMSDSoftheexistingeightcategoriesofchemicalproductstoconfirmwhethertheyincludethethreeelementsof"GHSclassification,signalwords,andprecautionarymeasures".
• Contactthecustomsbrokerandrequestthe"UNNumberandPackagingCompatibilityChecklist".Verifythepackagingofallrecentimportedgoodsonebyone.
• LogintotheofficialwebsiteoftheGeneralAdministrationofCustomsofChinaandcheckthebusinessscopeoftheenterprise’s"ImportDangerousChemicalsBusinessLicense"toseeifitcoversthechemicalproductsthatareabouttobeimported.