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On 8 February 2022 China’s Shanghai Maritime Safety Administration (MSA) issued a notice to clarify the declaration requirements for the composition of dangerous goods on ships entering and leaving the Waigaoqiao area (关于明确进出外高桥水域船载危险货物混合物组分申报要求的说明). This notice clarifies to the public what kind of toxic and dangerous chemicals are forbidden to be transported in the Yangtze River Basin waterway and what information the material safety data sheet (MSDS) should disclose in the shipment declaration when the goods contain a mixture of chemicals.
3E Review
According to Article 51 of China's Yangtze River Protection Law, the transport of very toxic chemicals and other dangerous chemicals by water is prohibited in inland river transportation (the "forbidden list") in the Yangtze River Basin. Although a CAS RN is often the only criterion to tell whether a chemical substance is forbidden from transport by water in the Yangtze River Basin, there is confusion about how to determine whether a mixture of chemicals is allowed for waterway transportation. To clarify this, the MSA issued this notice and also specified that the information disclosed by the MSDS plays an important role.
If the dangerous goods intended for shipment through the Waigaoqiao area of the Port of Shanghai are chemical mixtures, the MSA recommends that the MSDS submitted when filing the shipment declaration shows complete information about its ingredients, including each ingredient's name, concentration percentage, and CAS RN. If none of the ingredients are on the forbidden list, then the goods are allowed passage.
If the MSDS does not disclose complete ingredient information, or it shows complete ingredient information, but some ingredients are on the forbidden list, then the MSDS should also show the following three indicators:
- Health hazard – acute toxicity
- Hazard to aquatic environment – acute toxicity hazard
- Hazard to aquatic environment – long-term hazard
If any one of these three indicators is Category 1, then the good is prohibited from passing through the port.
Background Information
Very toxic chemicals refer to chemical substances that are marked as "very toxic chemicals" in the “Catalog of Hazardous Chemicals (2015 Version)” (危险化学品目录(2015版)实施指南(试行)中标注为“剧毒”的物质). Other dangerous chemicals that are prohibited by the state in inland river transportation are chemical substances that are listed in the “Catalog of Hazardous Chemicals Prohibited for Inland Waterway Transport” (内河禁运危险化学品目录(2019版)).
3E Analysis
Companies transporting dangerous goods in the Yangtze River Basin that contain a mixture of chemicals should note that China recently specified MSDS requirements for shipment declaration. Affected parties should review the notice and prepare in advance for compliance to avoid any unnecessary inconvenience when passing through the Waigaoqiao area.
For a copy of the source document (PDF, in Chinese), please contact us at Support@3Eco.com.
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