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Transportation of Dangerous Goods in China
Joanna Gao
Mar 12, 2024
China

Amid China’s booming economy and the burgeoning sectors of chemicals and civil explosives, there’s a marked escalation in the transportation needs for dangerous goods. Predictions for 2022 indicate a staggering 2 billion tonnes of such goods in transit, with chemicals alone comprising about 180,000 tonnes. This volume positions China among the top global handlers of hazardous materials. The nation employs a sophisticated multi-modal transport strategy—encompassing water, roads, railways, air, and pipelines—underpinned by a rigorous “Multi-department management system” to ensure the safe and efficient movement of dangerous goods including Ministry of Emergency Management(MEM), Management Ministry of Transport(MOT) and General Administration of Customs(GAC),Civil Aviation Administration(CAA), etc. 

1. Definition of Dangerous Goods 

According to the National Mandatory Classification and code of dangerous goods (GB 6944-2012), dangerous goods refer to substances and articles requiring specific protection that have such hazardous characteristics as explosivity, inflammability, toxicity, infectivity, corrosivity, and radioactivity, and may cause personal injury, property damage or environmental pollution during transport, storage, production, sales, usage, and disposal.This definition is derived from the UN Recommendations on the transport of dangerous goods-Manual of tests and criteria, 16 revision (TDG, also known as the “Orange Book”).

According to the Regulations on the Administration of Road Transport of Dangerous Goods (Order No. 13 of 2023 of the MOT), substances and articles with hazardous properties such as explosive, flammable, toxic, infectious and corrosive are classified as dangerous goods. These goods have the potential to cause damage to persons, property or the environment during production, handling, transport, storage, use or disposal and therefore require special protection.The transportation of dangerous goods shall be subject to the provisions listed in the Regulations concerning road transportation of dangerous goods (JT/T 617), and for those not listed in JT/T 617, shall be subject to the provisions of the relevant laws and administrative regulations or the results announced by the relevant departments of the State Council.

The definitions of dangerous goods in China’s transport regulations and standards employ varying descriptive terms, but largely in accordance with each other.

 

2. Classification and Transportation Labels

The classification of dangerous goods in China is also based on the TDG. According to the GB 6944-2012, dangerous goods are classified into 9 major groups based on their hazardous properties, as detailed in the table below:

Table 1: Classification of dangerous goods in China

Classification of Dangerous Goods Dangerous Goods Shipping Name
Class 1 Explosives
Class 2 Gas
Class 3 Liquid desensitized explosives
Class 4 Flammable solids, Self-heating substances and mixtures, Substances and mixtures which in contact with water
Class 5 Oxidizing substances and organic peroxides
Class 6 Acute toxicity, infectious substances
Class 7 Radioactive substances
Class 8 Skin corrosion
Class 9 Hazardous to the aquatic environment(environmentally hazardous substances)

Categories 1, 2, 4, 5 and 6 have been further divided into subcategories. Specific definitions and corresponding transport labels are given below:

Class 1 Explosives

Explosive materials, classified as "dangerous goods", include substances that can react chemically to produce gases and cause significant damage through heat, pressure, and speed. This category also encompasses pyrotechnics and items like fireworks and airbags, all subject to strict regulation due to their potential hazards.

Note that there six classes of Class 1 

Class 1.1 A substance or article with a mass explosion hazard.

Class 1.2 A substance or article with a fragment projection hazard, but not a mass explosion hazard.

Class 1.3 A substance or article which has a fire hazard along with either a minor blast hazard or a minor projection hazard or both, but not a mass explosion hazard.

Class 1.4 A substance or article which presents no significant hazard.

Class 1.5 A very insensitive substance which nevertheless has a mass explosion hazard.

Class 1.6 An extremely insensitive article which does not have a mass explosion hazard.

Table 2: Transport labels of Class 1

Class Transport Labels
Class 1.1, 1.2 and 1.3
Class 1.4
Class 1.5
Class 1.6

 

Class 2 Gases

Gases are substances that meet either of the following criteria: a) substances with a vapour pressure greater than 300 kPa at 50 °C; b) substances that are completely gaseous at a standard pressure of 101.3 kPa at 20 °C, for instance chlorine, helium, aerosol cans, etc.

Note that there are three classes of Class 2 :

Class 2.1 Flammable Gases

Class 2.2 Non-Flammable, Non-Toxic Gases

Class 2.3 Toxic Gases

Table 3:  Transport labels of Class 2

Class Transport Labels
Class 2.1 or
Class 2.2

                                                                   or

Class 2.3

 

Class 3 Flammable Liquids

This category encompasses dangerous goods in the form of liquid desensitized explosives. These are defined as liquids that are inherently flammable or comprise flammable liquid mixtures, as well as those that incorporate solids in solution or suspension. For classification as a flammable liquid, the substance must exhibit a flash-point not exceeding 60°C in a closed-cup test or 65.5°C in an open-cup test. Liquid desensitized explosives are specifically engineered homogeneous liquid blends, formulated by dissolving or dispersing explosive materials in water or other liquid media to mitigate their explosive characteristics. Various agents, including but not limited to paints, acetone, and perfumes, may serve as constituents in the formulation of liquid desensitized explosives within the realm of dangerous goods.

Table 4:  Transport labels of Class 3

Class Transport Labels
Class 3

or

 

Class 4 Flammable Solids; Substances prone to spontaneous combustion; Substances that emit flammable gases in contact with water

This category includes flammable solids, substances liable to spontaneous combustion and substances which emit flammable gases on contact with water. It includes substances other than those classified as explosives which are flammable under conditions of carriage or which may cause or lead to a fire, such as metal powders, white phosphorus, activated carbon, etc.

Note that there are three classes of Class 3:

Class 4.1 Flammable solids, self-reactive substances and solid desensitized explosives.

Class 4.2 Substances liable to spontaneous combustion

Class 4.3 A substance that, on contact with water, emits dangerous quantities of flammable gases.

Table 5: Transport labels of Class 4

Class Transport Labels
Class 4.1
Class 4.2
Class 4.3

or

 

Class 5 Oxidizing Substances and Organic Peroxides

This category encompasses substances with the inherent capacity to instigate or accelerate combustion, notably oxidizing substances and organic peroxides. Oxidizing agents, while not combustible in isolation, can significantly enhance the combustion of other materials through oxygen liberation. Organic peroxides, characterized by their bivalent peroxy (-O-O-) linkage, are organic compounds including but not limited to hydrogen peroxide, calcium hypochlorite, and 84 disinfectant.

Note that there are two classes of Class 5:

Class 5.1 Oxidising substances

Class 5.1 Organic peroxides

Table 6:  Transport labels of Class 5

Class Transport Labels
Class 5.1
Class 5.2

or

 

Class 6 Toxic Substances and Infectious Substances

This category pertains to materials deemed toxic or infectious. Toxic substances are identified by their potential to inflict harm or cause severe health consequences upon ingestion, inhalation, or dermal absorption, possibly leading to mortality or grave injury. Infectious substances are those known or presumed to harbor pathogens, such as paraquat, medical waste, and biological cultures.

Note that there are two classes of Class 6:

Class 6.1 Toxic Substances

Class 6.2 Infectious Substances

Table 7: Transport labels of Class 6

Class Transport Labels
Class 6.1
Class 6.2

 

Class 7 Radioactive Materials

This category is dedicated to materials containing radiosondes, including medical isotopes, Ammonium diuranate, and radiocobalt, which surpass specified activity concentration and total activity thresholds as per GB 11806.

Table 8: Transport labels  of Class 7

Class Transport Labels
7A
7B
7C
7E

Class 8 Corrosives

Corrosives are chemicals that have the potential to cause significant damage to living tissue on contact or to damage/destroy other items if spilled, including hydrochloric acid, caustic soda and batteries.

Table 9: Transport labels of Class 8 

Class Transport Labels
Class 8

 

Class 9 Miscellaneous Products, Substances or Organisms

This category applies to substances and articles that are considered to be hazardous but do not meet the criteria for any of the other categories. It includes items such as lithium battery packs, medical devices, environmentally hazardous substances, substances emitting flammable gases, etc.

Table 10:  Transport labels of Class 9 

Class Transport Labels
Class 9
9A

 

3. Determination

The classification of dangerous goods within China predominantly adheres to the standards set forth in GB 6944-2012 and the Dangerous Goods List (GB 12268-2012). For items not explicitly listed, precedence is given to relevant legal statutes, administrative regulations, or guidelines issued by pertinent State Council departments. GB 6944-2012 organizes dangerous goods into nine principal categories, each associated with packaging groups I, II, and III, while GB 12268-2012 enumerates 3,523 dangerous goods entries. However, regulations governing the road transport of dangerous goods (JT/T 617), along with the latest iterations of the International Maritime Dangerous Goods Code (IMDG) and the International Air Transport Association (IATA) regulations, take precedence over former standards due to their alignment with current regulatory and safety norms. Furthermore, dangerous goods generic determinations can be made based on whether a UN number is available or whether the classification can lead to the creation of a UN.

Please refer to the figure below for more information:

Figure 1: Determination of dangerous goods in China

 

4. Competent Authority

In contrast to other developed nations such as the United States and Canada, China has not yet implemented a comprehensive framework or standard for the integrated management of dangerous goods transportation across all modalities. Furthermore, there is an absence of a dedicated regulatory body tasked with the cohesive coordination and oversight of dangerous goods transport safety across various transport modes. Instead, the oversight of dangerous goods transportation is segmented, with respective regulatory bodies independently governing their specific domains according to their designated responsibilities.The authorizes responsible for supervision of dangerous goods may refer to the provisions of Regulations on the Safe Management of Hazardous Chemicals (Revised 2013-Decree No. 591).

The figure below shows the distribution of regulatory authorities and their responsibilities.

Figure 2: Regulatory Authorities for the Transportation of Dangerous Goods in China and the Distribution of Responsibilities

The Ministry of Emergency Management is responsible for the integral supervision and management of dangerous goods safety. National Transportation Authority is responsible for road/waterway transportation permits, the safety supervision of transportation vehicles and the qualification of road/waterway transportation enterprises/working staff. The National Railway Administration is responsible for the safety management of railway transportation for dangerous goods. The civil aviation administration is responsible for the management of the air transport of dangerous goods and the safety of air transport enterprises and their transport facilities. The Postal Administration shall be responsible for investigation on the delivery of hazardous chemicals. The Maritime Safety Administration is responsible for the safety management of hazardous chemicals loaded on ships and containers. The Public Security Department is responsible for public safety management of hazardous chemicals, the issuance of licenses for the purchase of highly toxic chemicals and the issuance of road transport permits, and also regulates the safety of transport vehicles. The State Administration for Market Regulation is responsible for issuing business licenses for enterprises that transport dangerous goods. For special categories of dangerous goods, such as  radioactive goods, the Nuclear Safety Regulatory Authority regulated them, with the participation of the relevant authorities of the State Council, such as MPS, MOT, NRA and CAA.

 

5. Legislative System

The regulatory landscape for dangerous goods in China is characterized by a multifaceted system comprising a blend of international conventions/regulations,national laws/administrative regulations, ministerial regulations, local regulations, standards and norms, etc.

The framework for the composition of the regulatory system is shown in the figure below.

Figure 3: Regulatory Framework for the Transportation of Dangerous Goods

For regulations involving the international transport of dangerous goods in China, the Technical Instructions for the Safe Transport of Dangerous Goods by Air (IATA) issued by the International Air Transport Association is applied for air transport, while the International Maritime Dangerous Goods Code (IMDG) issued by MSA is applied for maritime transport. International conventions and regulations provide the legal basis for inland transport, including road and rail transport. On the basis of the responsibilities defined in the Regulations concerning road transportation of dangerous goods (Revised in 2013), the regulatory authorities draft ministerial regulations, taking into account their own specificities and modes of transport. These departmental regulations, together with local regulations and national/industry standards, establish a network of regulatory systems. Below are the details of the regulations and standards for the management of dangerous goods in China.

 

5.1 Legislative System of Dangerous Goods Transport by Road

Administrative Regulation

  • The Regulations of the People's Republic of China on Road Transport, promulgated by Order No. 406 of The State Council on April 30, 2004, shall come into force on July 1, 2004. The latest version is the revised version promulgated on July 20, 2023. This administrative regulation provides for road transport operation, road transport-related business, international road transport, law enforcement supervision and legal liability, and the provisions of the regulation involve constraints and penalties on the transport of dangerous goods.

Departmental Regulation

  • The Provisions on the Administration of Road Transport of Dangerous Goods were issued by Decree No. 2 of 2013 from the Ministry of Transport on January 23, 2013, valid from July 1, 2013. The last revised version was issued on November 10, 2023. It regulates licensing, special vehicles and equipment, dangerous goods transport, supervision and inspection, and legal liability. It is the primary departmental regulation governing the transportation of dangerous goods by road.
  • The Regulations on the Safe Management of Road Transportation of Dangerous Goods (MOT Order No. 29 of 2019), published on November 10, 2019, applicable from January 1, 2020.The MOT, Ministry of Ecology and Environment (MEE), MEM, and SAMR jointly issued regulations to enhance the management of consignment, carriage, loading, and unloading of dangerous goods in road transport. The management requirements for exceptions in road transport, limited quantity of hazardous goods, etc., have been delineated. The safety management of equipment for hazardous goods road transport is enhanced. Standardized measures for controlling hazardous goods road transport vehicles are specified. The regulatory responsibilities and collaborative requirements of various departments regarding hazardous goods road transport are clarified.

Technical Standard

  • Regulations concerning road transportation of dangerous goods (JT/T 617) is an industry standard published by the MOT on August 29, 2018 and implemented from December 1, 2018.This standard consists of seven parts that focus on the transportation of dangerous goods in part 1-6 and part 8-9,including: General Provisions (JT/T 617.1); Classification (JT/T 617.2); Index of Dangerous Goods Name and Transportation Requirement (JT/T 617.3); Provisions for the Use of Transport Packagings (JT/T 617.4); Consignment (JT/T 617.5); Provisions concerning the Conditions of Carriage, Loading, Unloading and Handling (JT/T 617.6); and Transport Conditions and Operational Requirements (JT/T 617.7).

Refer to the table below for details.

Table 11: Components of Regulations concerning road transportation of dangerous goods (JT/T 617)

Standard Name Standard No.

Regulations concerning road transportation of dangerous goods-

Part 1:General provisions
JT/T 617.1-2018

Regulations concerning road transportation of dangerous goods-

Part 2:Classification
JT/T 617.2-2018

Regulations concerning road transportation of dangerous goods-

Part3:Index of Dangerous Goods Name and Transportation Requirement
JT/T 617.3-2018

Regulations concerning road transportation of dangerous goods-

Part 4 :Provisions for the Use of Transport Packagings
JT/T 617.4-2018

Regulations concerning road transportation of dangerous goods-

Part 5:Consignment
JT/T 617.5-2018

Regulations concerning road transportation of dangerous goods-

Part6:Provisions concerning the Conditions of Carriage, Loading, Unloading and Handling
JT/T 617.6-2018

Regulations concerning road transportation of dangerous goods-

Part 7 : Transport Conditions and Operational Requirements
JT/T 617.7-2018

JT/T 617-2018 is aligned with international standards, referencing the UN TDG (Revision 18) Model Regulations, the United Nations Recommendations on the Transport of Dangerous Goods: Tests and Criteria (Revision 6), and the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR 2015 edition). The relevant standards are being refined and improved to address dangerous goods issues such as tank and media compatibility, transport vehicles, loading procedures and transport operations.

  • The vehicle mark for road transportation dangerous goods (GB 13392-2005) is a national mandatory standard that specifies the classification, specifications, dimensions, technical requirements, test methods, inspection rules, packaging, marking, loading, unloading, transportation, and storage of signs for vehicles carrying dangerous goods by road and has been in effect since August 1, 2005.In addition to installing and maintaining hanging requirements, this standard applies to the production, use and management of road transportation of hazardous materials vehicle signs. On September 8, 2023, SAMR and the Standardization Administration of the P.R.C. (SAC) issued GB 13392-2023, which will replace GB 13392-2005 starting at April 1, 2025. 
  • Safety code for inspection of packaging of dangerous goods transported by road (GB 19269-2009) is a mandatory national standard that has been in effect since May 1, 2010. This standard specifies the classification, code, and marking of packaging for the road transport of dangerous goods (excluding military goods), as well as the requirements, performance testing, and identification use applicable to Chapter 4 of the standard. This applies to all categories except for Category 2, Category 6, Item 6.2, and Category 7. The standard does not apply to the road transport of dangerous goods packaging inspection.
  • Safety specifications for road transportation vehicle of explosive substance and chemical toxic substance is subject to national mandatory standards, which have been in effect since July 1, 2018. This standard outlines the concepts and definitions, requirements, markings and accompanying documents for road transportation vehicles of explosives and highly toxic chemicals. It applies to all vehicles and trailers transporting explosives and highly toxic chemicals on the road.
  • The MOT published Safety technical specifications for commercial vehicles for road transport of dangerous goods on February 28, 2020. The effective date of this standard is April 1, 2020. This standard specifies the classification of vehicles used for transporting dangerous goods on roads, as well as the basic, general, and special safety requirements and test methods. It applies to N vehicles, O semi-trailers, semi-trailer tractors, and semi-trailer trains used for transporting dangerous goods.

 

5.2 Legislative System of Dangerous Goods Transport by Railway

Law/Administrative Regulation

  • The Law of the People’s Republic of China on Railways, issued by Presidential Decree No. 32 on September 7, 1990, has been in effect since May 1, 1991. The latest version, issued on April 24, 2015, regulates rail transportation of dangerous goods and establishes legal liability. It is the national law governing rail transportation of dangerous goods.
  • The Railway Safety Management Regulations (State Council Decree No. 639) came into force on January 1, 2014. This administrative regulation pertains to the railroad transportation of dangerous goods, focusing on safety management and safe transportation. The regulation delineates the regulatory framework, operational standards, and legal obligations pertinent to the rail conveyance of dangerous goods.

Departmental Regulation

  • The Provisions on Supervision and Administration of Transport Safety of Railway Dangerous Goods were published on September 26, 2022, and entered into force on December 1, 2022, replacing the version of 2015. This regulation stipulates the conditions for the transportation, safety management, supervision, and legal responsibilities pertaining to the rail transport of dangerous goods within the territory of China. It serves as the principal ministerial regulation governing the safe transport of dangerous goods by rail.

Technical Standard

  • The List of dangerous goods in railway,which is an industry standard, was issued by the NRA on October 25, 2022, and implemented on May 1, 2023. This standard stipulates the general provisions for the nomenclature of dangerous goods, the structure of the dangerous goods nomenclature table, and the table itself, applicable to the transportation of dangerous goods by rail.
  • The Packaging of dangerous goods transported by railway is subject to industry standards. These standards were published by the NRA on December 21, 2020, and implemented on July 1, 2021.This standard specifies the fundamental technical requirements for the packaging of dangerous goods for rail transport, including the basic requirements for various types of dangerous goods packaging, common combinations, packaging illustrations and requirements, as well as performance testing. It is applicable to the inspection, design, and use of packaging for the transport of dangerous goods by rail, but does not cover packaging with special requirements for dangerous goods.
  • The Safety Code for Inspection of Packaging of Dangerous Goods Transported by Railway (GB 19359-2009) is a national mandatory standard. It was promulgated by General Administration of Quality Supervision, Inspection and Quarantine of China (AQSIQ) and SAC on June 21, 2009, and implemented from May 1, 2010. This standard specifies the classification, coding, and marking requirements, performance testing, and usage evaluation for the packaging of dangerous goods transported by rail (excluding military items). It applies to the inspection of packaging for dangerous goods transported by rail as outlined in Chapter 4, with the exception of Class 2, Section 6.2 of Class 6, and Class 7, and does not apply to pressure vessels, packages with a net weight exceeding 400kg, or packages with a volume exceeding 450L.
  • Classification test method of railway dangerous goods was published on May 10, 1996 and implemented on November 10, 1996. It is an industry standard that is still used today. This standard prescribes the classification, item division, test methods, and categorization values for dangerous goods in rail transport, applicable to the determination of new product categories of dangerous goods by rail.

 

5.3 Legislative system of dangerous goods transport by civil aviation

International Conventions/Law

China has adopted international conventions for transporting dangerous goods by air to help ensure international uniformity. These include: the Regulations for Safe Transport of Radioactive Material (IATA), the Regulations for Safe Transport of Radioactive Material issued by the International Atomic Energy Agency (IAEA), and the Convention on the Safe Transport of Radioactive Material issued by the International Civil Aviation Organization (ICAO), and the implementing guidelines Technical Instructions for the Safe Transport of Dangerous Goods By Air. International Civil Aviation Annex 18, as well as Technical Instructions for the Safe Transport of Dangerous Goods By Air, issued by the International Civil Aviation Organization (ICAO). This convention is based on the UN TDG and incorporates the unique features of air transportation to form a more stringent system of technical requirements. Nevertheless, in terms of classification, packaging, labeling and other core contents of dangerous goods, it is consistent with the requirements of other modes of international transportation.

Administrative Regulation

  • Civil Aviation Law of the People’s Republic of China enacted on October 1995 and implemented from March 1, 1996, with its latest amendment on April 29, 2021, specifies the requirements and legal responsibilities for public air transport enterprises regarding the transportation of dangerous goods. This law serves as the national legal framework for the air transport of dangerous goods.
  • The Decision of the State Council on Establishing Administrative License for the Administrative Examination and Approval Items Really Necessary to Be Retained, revised in August 2016, specifies a catalog of administrative approval items that require administrative licensing. This includes the approval of qualifications for air operators to transport dangerous goods.

Departmental Regulation

  • China’s Civil Aviation Transportation Of Dangerous Goods Regulations published by MOT No. 42 of 2016 on April 13, 2016. The regulations define the management of air transport of dangerous goods within China’s civil aviation, covering permit procedures, and outlining the responsibilities of shippers and operators, applicable to both domestic and international air transport entities involved in handling dangerous goods. The MOT updated its regulations on the management and transportation of dangerous goods, effective from July 1, 2024.
  • The CAA issued the Administrative Measures for the Temporary Storage of Dangerous Goods Transported by Air on December 20, 2022, which took effect on March 1, 2023.The regulations issued by the authority establish fundamental, interim storage, additional requirements, and supervisory measures for the air transport of dangerous goods, applicable to carriers and ground service agents engaged in temporary storage activities for such goods.
  • The 2021 edition of the List of Dangerous Goods for Air Transport in China was published and implemented by CAAC on March 22, 2021, replacing the 2019 edition.The List outlines the specifications for air transport of dangerous goods, covering their identification, classification, and packaging standards to ensure aviation safety.
  • The Air Cargo Handling and Loading Standards issued by the CAA on August 9, 2023, stipulate requirements for the handling and loading of dangerous goods, including the transmission and preservation of information. 

Technical Standard

  • Specification for transport of lithium batteries by air is the industry standard for the transportation of lithium batteries by air. This standard was published by CAAC on March 27, 2018, and became effective on June 1, 2018, replacing the 2013 version.This standard specifies the restrictions and operational guidelines for the air transport of lithium batteries, applicable to the air transport of lithium battery cargo and baggage, but not to the air mail transport of lithium batteries.
  • Tests for combination packaging and packages of dangerous goods in limited quantities which is an industry standard. It has been implemented since May 1, 2014. This standard outlines the criteria and testing for packaging designed to safely contain limited quantities of dangerous goods, ensuring compliance and safety in their handling and transportation.
  • Specification of packaging requirements and tests for packages of dangerous goods in excepted quantities (MH/T 1057-2014), which is an industry standard. It has been implemented since June 1, 2015. This standard specifies the general technical requirements, packaging test requirements, testing methods, and reporting for dangerous goods packaged in excepted quantities. It is applicable to the packaging and testing of dangerous goods in excepted quantities but does not cover the packaging and testing of excepted packages for radioactive materials.
  • Special requirements for dangerous goods air transport pre-production prototypes and low production runs of lithium batteries or cells which is an industry standard. It has been implemented since October 1, 2020. This standard outlines the testing procedures for prototype and low volume lithium batteries or battery cells, as well as the drop test methods for their packages, in accordance with the Aviation Transport of Dangerous Goods Approval and Exemption Management Procedure. It is applicable to prototype and low production lithium batteries or battery cells that are classified as dangerous goods cargo.
  • Tests for lithium batteries transported by air which is an industry standard. It has been implemented since May 1, 2013. This standard outlines procedures for testing lithium batteries prior to air transportation, including a 1.2m drop test and requirements for test reports. Additionally, it defines conditions for identifying lithium battery cargo eligible for air transportation. It ensures compliance and safety in the transport of lithium battery cargo by air.

 

5.4 Legislative system of dangerous goods transport by waterway and port

Law/Administrative Regulation

Port:

The Law of the People’s Republic of China on Ports was first published on June 28, 2003, and the latest version was published on December 29, 2018.This regulation pertains to the handling of dangerous goods during vessel entry and exit at ports, as well as the loading, unloading, and transshipment operations of dangerous goods within port premises.

Vessel:

The latest edition of the Maritime Traffic Safety Law of the People’s Republic of China was published on April 29, 2021, and came into force on September 1, 2021. This legislation provides comprehensive guidelines for the supervision, management, and legal obligations concerning the transportation of dangerous goods in maritime operations within the jurisdictional waters of China. It encompasses various aspects such as the carriage and handling of hazardous cargo by vessels, consignment procedures by shippers, vessel movements in and out of ports carrying dangerous goods, and the safe execution of loading, unloading, and transshipment activities involving dangerous goods at sea.

Container:

The Regulations of the People’s Republic of China on Administration of Traffic Safety in Inland Rivers(2019 Revision) which became effective on August 1, 2002. The regulations govern various aspects of navigation, operations, and safety measures concerning inland waterway transportation in China. They strictly prohibit the transportation of dangerous goods as stipulated by relevant laws, regulations, and the competent transportation authorities. Chinas List of Hazardous Chemicals Prohibited from Inland Waterway Transport (2019) contains specific rules.

Departmental Regulation

Port:

  • In 2017, the Provisions on the Safety Management of Hazardous Goods at Ports (2023 Amendment) were published and implemented by the MOT. This regulation outlines the framework for safety, management, and legal responsibilities related to the construction and operation of dangerous goods facilities at Chinese ports, serving as the key guideline for dangerous goods transportation at these locations.
  • In 2021, the Measures for the Supervision and Administration of Major Hazard Installations of Dangerous Goods at Port was published and implemented by the MOT. This regulation stipulates the identification, assessment, registration, record-keeping, safety management, and inspection of major hazardous sources of dangerous goods in ports. It applies to the identification, evaluation, documentation, record-keeping, cancellation, and supervisory management of major hazards associated with dangerous goods in port areas.
  • In 2016, the Guidelines for the Supervision and Inspection of Dangerous Goods Safety in Ports was published and implemented by the MOT. This guide outlines the regulatory framework for safety inspections of dangerous goods port operators, detailing the standards for inspection entities, methodologies, and operational safety oversight by port authorities.
  • In 2016, the Guidelines for the Identification of Major Accident Hazards in Dangerous Goods Port Operations was published and implemented by the MOT. The guidelines stipulate the scenarios of significant accident risks associated with the handling of dangerous goods in port areas and are applicable to operations involving hazardous materials within port jurisdictions. They also serve to guide port operators and port administrative authorities in identifying major accident hazards in the handling of dangerous goods at ports.
  • In 2017, the Guidelines for Safety Risk Assessment of Concentrated Areas of Dangerous Goods in Ports was published and implemented by the MOT. The guide outlines protocols for assessing safety risks associated with dangerous goods in ports, covering established storage, handling areas, and projects involving new or expanded facilities, ensuring comprehensive regional risk evaluations.

Vessel:

  • In 2018, the Regulations on the Safety Supervision and Management of the Carriage of Dangerous Goods by Ships was published and implemented by the MOT. This regulation outlines the management and safety protocols for the maritime transport of dangerous goods within China’s jurisdictional waters, serving as the primary guideline for such activities.

Container

  • The Provisions of the People’s Republic of China on Inland-Water-Related Maritime Administrative Penalties(2022 Amendment) was published by the MOT in May 2015 and became effective on July 1, 2015. The regulation on stipulates maritime administrative penalties for violations of maritime administrative order in inland water areas and related land areas within China, covering aspects such as the safety supervision and management of the carriage of dangerous goods.

Technical Standard                                                                                                                                       

  • Safety Code for Inspection of Packaging of Dangerous Goods for Waterway Transport (GB 19270-2009), which belongs to the national standard, has come into force since May 1, 2010. This standard sets the guidelines for classification, coding, and marking of waterway-transported dangerous goods packaging, excluding Classes 2, 7, and 6.2, focusing on their requirements, testing, and evaluation.
  • Technical Requirements for Safety of Shipping Dangerous Goods Containers (GB 40163-2021), which belongs to the national standard, will come into force on November 1, 2021. This standard specifies the basic requirements, pre-packing preparation, packing and sealing operation requirements, post-packing requirements, records and documents requirements for shipping containers of dangerous goods. It is applicable to the packing operation of ships carrying dangerous goods.
  • Safety requirements for port operation. Part 3:Dangerous cargo containerGB 16994.3-2021which is a national standard. It has been implemented since December 1, 2022. This standard specifies the general requirements, pre-operation requirements, loading and unloading operation requirements, storage operation requirements, container packing and unpacking requirements, emergency requirements, and operational information requirements for the handling of dangerous goods in container terminals. It is applicable to the port operations involving containers of dangerous goods, ensuring safety and compliance in the handling process.

In addition to the regulatory standards for different modes of transport listed above, there are some comprehensive regulatory standards involving multiple departments and multiple modes of transport, such as:

In the export link, dangerous goods must meet the provisions of the Law of the People's Republic of China on Import and Export Commodity Inspection and the Implementation Regulations of the Law of the People's Republic of China on Import and Export Commodity Inspection, that is, enterprises producing packaging containers for export dangerous goods need to apply for performance appraisal, and enterprises producing export dangerous goods need to apply for use appraisal.

China has specific laws and administrative regulations to manage certain types of dangerous goods, including civil explosive substances, fireworks, and radioactive substances, such as Regulations on the Safety Control of Civil Explosives, Regulation on the Safety Administration of Fireworks and Firecrackers and Regulation on the Administration of Transport Safety of Radioactive Articles.

National regulations govern how dangerous goods are named, classified, packaged and shipped including

(1) Principles for Naming Dangerous Goods(GB/T 7694-2008

(2) Classification Method of Dangerous Goods Transport Packaging(GB/T 15098-2008

(3) Dangerous Goods Packing Mark (GB 190-2009)

(4) General Technical Conditions for the Transportation and Packaging of Dangerous Goods (GB 12463-2009)

(5) Structural Requirements for Dangerous Goods Transport Vehicles (GB 21668-2008)

(6) Basic Provisions on Inspection Standards for Dangerous Goods and Packaging of Dangerous Goods (GB/T 19459-2004)

(7) Basic Procedures for Classification and Grading of Dangerous Goods (GB 21175-2007)

(8) Pictorial Signs for Packaging, Storage and Transportation (GB/T 191-2008)

(9) List of Dangerous Goods (GB 12268-2012)

(10) Classification and Designation Number of Dangerous Goods (GB 6944-2012)

(11)  Exceptional Quantity and Packing Requirements for Dangerous Goods (GB 28644.1-2012)

(12) Limited Quantity and Packing Requirements of Dangerous Goods (GB 28644.2-2012)

(13) Classification and List of Organic Peroxides (GB 28644.3-2012)

(14) Chemical Reagent-Packaging and Marking (GB 15346-2012)

 

6. Regulation Development

China has been developing regulations and standards for transporting dangerous goods for many years, yet it remains inadequate. China is refining its dangerous goods transportation regulations by incorporating international best practices and national specifics to strengthen its oversight system.

The drafts of two mandatory national standards, GB 12268 and GB 6944, released on March 1, 2023, are currently closed for comments on the transportation of dangerous goods. The revised GB 12268 and GB 6944 aligns with the UN TDG (Revision 22). Once formally published and implemented, GB 12268 will replace GB 12268-2012 and GB 6944-2012. In July 2023, the NRA issued Technical requirement for railway transport of dangerous goods (TB/T 30008-2023), which came into effect on February 1, 2024.

On November 30, 2023, the Shanghai Maritime Safety Bureau of China issued the Shanghai Port Guidelines for the Waterway Transportation of Lithium Battery Dangerous Goods. The guidelines outline provisions and explanations for terminology, classification, labeling, packaging, and safety requirements related to lithium battery dangerous goods.

SAMR and AQSIQ jointly issued the "Port Operation Safety Requirements Part 6: Solid Bulk Dangerous Goods (Draft for Comment)" (GB 16994.6-XXXX) on August 17, 2023, and the comment solicitation has been closed. This standard outlines the inaugural national mandatory regulations for port operations involving solid bulk dangerous goods, detailing requirements for handling, horizontal transport, stacking, emergency management, etc.

On September 25, 2023, the Road Transportation Board released Revision Sheet No. 1 (Draft for Comment) for the JT/T 617.1 to JT/T 617.6 series of industry standards. The comment period has now ended. The revision of this batch is focused on meeting the needs of road transportation management for dangerous goods. The aim is to improve technical advancement and applicability of the standard while ensuring good connection with ADR (Authorization Dangerous Road 2023 Edition) and other relevant regulations.

In October 2020, the MEM released the draft for consultation of the People’s Republic of China Dangerous Goods Chemical Safety Law, which is currently closed for comments. This law is based on the Regulations Concerning Road Transportation of Dangerous Goods (Revised in 2013). Once officially published, it will be China’s primary dangerous chemicals law. This law mandates comprehensive safety management for the production, storage, use, operation, transportation, and disposal of dangerous goods, covering aspects from registration to emergency response and legal accountability.

In 2023, the MOT, as the main authority for the transportation of dangerous goods, amended the regulations for different modes of transportation. These include “The Provisions on the Administration of Road Transport of Dangerous Goods", “The Regulation of the People’s Republic of China on International Ocean Shipping”, “Provisions on the Administration of Road Transportation of Radioactive Articles”, etc. The MOT amended the Provisions on the Administration of the Transport of Dangerous Cargo by Civil Aviation, which will come into effect on July 1, 2024.Furthermore, the MSA has issued a notice implementing Amendments 41-22 to the International Maritime Dangerous Goods Code and Amendments 06-22 to the International Maritime Solid Bulk Cargoes (IMSBC) Code. ChemRadar will update the relevant regulations and standards based on the current situation.

Overall, the regulatory framework for the transportation of dangerous goods in China is continuously evolving and improving, aligning with international standards to ensure the safe and efficient transport of such goods within the country.

 

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Joanna Gao
ChemRadar Regulatory Analyst
CONTENTS
1. Definition of Dangerous Goods
2. Classification and Transportation Labels
3. Determination
4. Competent Authority
5. Legislative System
6. Regulation Development
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