Complete Process Guide for Export of Class 9 Dangerous Goods

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Complete Process Guide for Export of Class 9 Dangerous Goods

Date:2023-11-09

Class 9 Dangerous Goods refer to Miscellaneous Dangerous Substances and Articles, which are substances and articles with dangerous characteristics not covered by other classes. Common categories include dry ice (solid carbon dioxide), magnetic substances, lithium batteries (including lithium metal batteries and lithium-ion batteries), asbestos products, equipment containing polychlorinated biphenyls (PCBs), etc. Due to the diverse dangerous characteristics of such goods, the export process must strictly comply with the International Maritime Dangerous Goods Code (IMDG Code) and relevant regulatory requirements of the country of origin and the destination country. The following is the complete operation process and key precautions for the export of Class 9 Dangerous Goods, helping enterprises efficiently and compliantly complete export business.

 

  1. Pre-preparation: Verification of Basic Qualifications and Documents

 

  1. Confirmation of Enterprise Qualifications

 

Export enterprises shall hold the Registration Form for Foreign Trade Operators, complete the registration of consignor/consignee of import and export goods with the customs, and obtain the customs declaration right. If the exported goods are self-produced by a production-oriented enterprise, it is necessary to ensure that the production process complies with relevant regulations on the safety management of hazardous chemicals; if it is a trade-oriented enterprise, it is necessary to verify that the supplier has the corresponding production or operation qualifications. In addition, the export of Class 9 Dangerous Goods shall entrust freight forwarders or logistics enterprises with dangerous goods transportation qualifications (especially experience in handling corresponding sub-categories), such as choosing logistics providers familiar with UN38.3 test requirements for transporting lithium batteries.

 

  1. Verification and Classification of Goods Information

 

Clarify the core attributes of the goods, including product name, composition/structure, dangerous characteristics (such as magnetic strength, lithium battery capacity/energy, whether it contains flammable components, etc.), UN number (e.g., dry ice UN1845, lithium-ion batteries UN3480, magnetic substances UN2807), dangerous class (Class 9), and packaging class (some Class 9 goods have no packaging class, and some need to be divided according to specific requirements). Determine the HS code through the Catalogue of Hazardous Chemicals and HS coding classification rules, and verify whether a special export license is required (e.g., the export of asbestos products must comply with relevant environmental protection licensing requirements, and the export of lithium batteries must abide by UN38.3 tests and air/sea transportation restrictions).

 

  1. Preparation of Core Documents

 

Necessary documents include: ① Commercial Invoice; ② Packing List; ③ Customs Declaration Form; ④ Inspection Result Sheet for the Use of Dangerous Goods Packaging (Dangerous Goods Packaging Certificate; some Class 9 goods such as dry ice and magnetic substances require special packaging and appraisal by the inspection and quarantine department); ⑤ Safety Data Sheet (SDS/MSDS, including 16 standard items, clarifying the dangerous characteristics, emergency disposal methods and transportation requirements of the goods); ⑥ Special test reports (e.g., UN38.3 test report for lithium batteries, magnetic field strength test report for magnetic substances); ⑦ Sales Contract; ⑧ Certificate of Origin (provided when required by the destination country). If the goods involve special supervision (such as environmental protection and security inspection), corresponding license documents need to be supplemented.

 

  1. Packaging and Labeling: Targeted Compliance Assurance

 

  1. Selection and Inspection of Packaging

 

Class 9 Dangerous Goods shall use UN standard special packaging according to specific categories: for example, dry ice shall use leak-proof and breathable thermal insulation packaging to avoid packaging rupture caused by carbon dioxide gas generated by sublimation; lithium batteries shall use short-circuit-proof and collision-proof packaging (such as independent packaging + buffer materials to avoid contact between positive and negative electrodes); magnetic substances shall be packaged with magnetic shielding to ensure that the magnetic field strength meets transportation standards (magnetic field strength ≤ 0.159 Tesla at 2.1 meters from the packaging surface). After packaging, it is necessary to entrust the inspection and quarantine department to conduct packaging performance inspection and use appraisal, and obtain the Dangerous Goods Packaging Certificate. Goods without qualified packaging shall not be exported.

 

  1. Loading of Goods and Posting of Labels

 

Protective measures shall be taken during loading according to the characteristics of the goods: for example, dry ice loading shall reserve breathable space to avoid pressure increase in sealed containers; lithium batteries shall avoid stacking and extrusion, and shall not be mixed with sharp objects. For container transportation, special dangerous goods containers shall be used. The general label for Class 9 Dangerous Goods (gray diamond marked with “Miscellaneous Dangerous Substances”) and corresponding sub-category labels (such as lithium battery label, dry ice label) shall be posted inside the container, and dangerous goods signs and emergency contact numbers that meet international standards shall be hung outside the container. Meanwhile, the information of the consignee and consignor, UN number and net weight of the goods (such as the loading capacity and sublimation rate of dry ice) shall be clearly marked on the outer packaging.

 

III. Booking and Transportation: Matching Sub-category Requirements

 

  1. Selection of Freight Forwarder and Submission of Booking Documents

 

Choose a freight forwarder with experience in handling sub-categories of Class 9 Dangerous Goods (e.g., familiar with IATA rules for air transportation of lithium batteries, and understanding maritime department’s magnetic field restrictions for transportation of magnetic substances), and submit booking documents: Booking Note, SDS/MSDS, Dangerous Goods Packaging Certificate, special test reports (such as UN38.3), Goods List, etc. The freight forwarder shall confirm the acceptability of the goods with the shipping company/airline (e.g., some airlines have restrictions on the energy density of lithium batteries, and some shipping companies prohibit dry ice from being transported in the same cabin as certain dangerous goods), and submit complete dangerous goods declaration materials.

 

  1. Dangerous Goods Declaration and Confirmation of Shipping Space

 

The freight forwarder assists the enterprise in going through the dangerous goods declaration procedures with the maritime department (for sea transportation) or civil aviation administration (for air transportation), and submits the Dangerous Goods Declaration Form, SDS/MSDS, test reports, Dangerous Goods Packaging Certificate and other materials. The declaration of Class 9 Dangerous Goods shall focus on explaining the dangerous characteristics of the goods and prevention and control measures (such as explaining the magnetic shielding effect for magnetic substances, and the breathable measures for dry ice). After passing the review, the shipping company/airline confirms the shipping space. The declaration must be completed 3-5 working days in advance (longer in advance for air transportation) to avoid affecting the loading plan.

 

  1. Inland Transportation and Loading

 

Arrange vehicles with dangerous goods transportation qualifications for inland transportation, and abide by special regulations during transportation: for example, dry ice transportation shall control the transportation time to avoid premature sublimation; magnetic substances transportation shall avoid routes for precision instruments; lithium batteries transportation shall limit speed and be equipped with fire-fighting equipment. After the goods are transported to the port/airport, they are received by the special dangerous goods yard/warehouse. After passing the inspection by the inspection and quarantine department (focusing on verifying the compliance of packaging, completeness of labels, and validity of test reports), loading is arranged. The loading process must be operated by professional personnel, such as wearing protective gloves for dry ice loading and handling lithium batteries with care.

 

  1. Customs Declaration and Inspection: Completion of Customs Clearance Procedures

 

  1. Inspection Process (if required)

 

According to national regulations, some Class 9 Dangerous Goods (such as asbestos-containing products and radioactive miscellaneous substances) need to go through inspection procedures before export. Submit the Inspection Application Form, SDS/MSDS, Dangerous Goods Packaging Certificate, special test reports, Contract, Invoice and other materials to the inspection and quarantine department, and obtain the Customs Clearance Certificate for Export Goods after passing the inspection.

 

  1. Customs Declaration Process

 

Submit customs declaration materials to the customs, including: Customs Declaration Form, Commercial Invoice, Packing List, Contract, Dangerous Goods Packaging Certificate, SDS/MSDS, special test reports, Customs Clearance Certificate for Export Goods (if any), license documents (if any), etc. When reviewing the materials, the customs focuses on verifying the accuracy of goods classification, the authenticity of dangerous characteristics declaration, and the compliance of packaging and labels, and may conduct on-site inspection if necessary. After verification, the tax collection (if any) and release procedures are completed.

 

  1. Customs Clearance at Destination Country and Follow-up

 

  1. Preparation of Customs Clearance Documents for Destination Country

 

Provide the foreign customer with the documents required for customs clearance at the destination country in advance, including: Commercial Invoice, Packing List, SDS/MSDS (complying with the standards of the destination country, such as REACH regulations for the EU), special test reports, Certificate of Origin, Dangerous Goods Label Confirmation Document, etc. Different countries have special requirements for Class 9 Dangerous Goods: for example, the EU requires an additional UN38.3 test report and CE certification for the import of lithium batteries; the United States requires advance notification to the FDA for dry ice transportation; some countries prohibit the import of asbestos-containing products, which need to be verified in advance.

 

  1. Goods Tracking and After-sales Service

 

After the goods are loaded on board/aircraft, the freight forwarder provides the Bill of Lading or Air Waybill to the enterprise. The enterprise sends the documents and customs clearance materials to the foreign customer to assist in completing customs clearance at the destination country. Track the transportation status of the goods and timely handle problems according to the characteristics of Class 9 Dangerous Goods: for example, track the temperature change during dry ice transportation to avoid affecting the quality of goods due to complete sublimation; pay attention to whether there are abnormalities such as leakage and heating during lithium battery transportation. After the delivery of the goods, sort out the export documents and complete subsequent work such as foreign exchange settlement and tax refund.

 

  1. Key Precautions

 

  1. Precise Control of Sub-categories: Class 9 Dangerous Goods cover a wide range, and the dangerous characteristics of different sub-categories vary greatly (such as the low-temperature asphyxiation risk of dry ice, the combustion and explosion risk of lithium batteries, and the equipment interference risk of magnetic substances). Targeted packaging, transportation and declaration plans shall be formulated to avoid violations caused by “one-size-fits-all”.

 

  1. Validity of Test Reports: Special test reports such as UN38.3 test for lithium batteries and magnetic field strength test for magnetic substances must be issued by qualified institutions and within the validity period to avoid customs clearance delays or goods detention due to non-compliant reports.

 

  1. Adaptation of Transportation Methods: Different transportation methods have different restrictions on Class 9 Dangerous Goods (e.g., air transportation has stricter energy restrictions on lithium batteries than sea transportation, and dry ice air transportation must comply with IATA requirements for breathable packaging). It is necessary to choose an appropriate transportation method according to the characteristics of the goods.

 

  1. Pre-verification of Destination Country Regulations: Class 9 Dangerous Goods have import bans or strict restrictions in some countries (e.g., some countries prohibit the import of Class 9 goods containing PCBs). It is necessary to verify the relevant regulations of the destination country before signing the contract to avoid failure to clear customs after export.

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