What special safety management requirements are there for packaging when exporting hazardous chemicals?

In 2026, the national special rectification campaign for exporting hazardous chemicals at ports will be fully advanced, with the new version of the "Inspection Procedures for Export Dangerous Goods Packaging" and IMDG 42-24 international maritime hazardous regulations implemented. Customs will strengthen full-chain safety verification of export hazardous chemical packaging. For liquid corrosive and flammable hazardous chemicals, it is clearly stated that 1H1 closed-mouth plastic barrels with full UN certification must be legally compliant packaging. Ordinary plastic barrels, open-mouth barrels, and refurbished recycling barrels without certification are strictly prohibited from being used for hazardous chemical export transportation. Recently, multiple ports have repeatedly uncovered cases of non-compliant export of UN closed-mouth plastic barrels, and all related goods are not allowed to be disposed of for export

Recently, Huangdao Customs, under Qingdao Customs, seized a batch of non-compliant Category 8 types of corrosive hazardous chemical reverse osmosis scale inhibitors during the export container inspection process. The goods were stored in 200L closed-mouth plastic drums, totaling 100 barrels and weighing 2.5 tons. When on-site customs officers compared documents, they found that the UN mark, packaging grade, and compatibility density parameters cast on the barrel body did not match the information submitted by the company in the "Export Dangerous Goods Transport Packaging Usage Assessment Report." It was determined that this batch of UN closed-mouth plastic barrels had not completed standardized usage appraisal, making corrosion, leakage, and barrel body cracking highly prone to corrosion, leakage, and barrel rupture during transportation. Customs refused export of the entire batch of goods and required the company to replace it with brand-new compliant UN1H1 standards Closed-mouth plastic barrels and complete a full set of packaging appraisal before they can be declared to the Guangdong Branch of the General Administration of Customs of the People's Republic of China.

Similarly, Shaoxing Customs, under Hangzhou Customs, seized a batch of flammable corrosive liquids loaded in deformed UN closed-mouth plastic barrels during a 100-day hazardous chemical inspection. On-site inspection revealed that multiple 1H1 closed-end plastic barrels had dented top lids and barrel bodies deformed under pressure, with stacking stability substandard and not meeting UN mandatory packaging stacking and drop test standards. There was a risk of collapse and leakage from ship hold stacking. The packaging was also judged to be unqualified and release was temporarily suspended from the Guangdong branch of the General Administration of Customs of the People's Republic of China. Hanyang Customs has previously investigated cases of UN closed-mouth barrels exceeding density standards. The actual density of hazardous chemicals filled by companies exceeded the UN labeling limits on the barrel body, and the barrels lacked sufficient pressure capacity, leading to interceptions at ports, sounding the compliance alarm for many foreign trade enterprises.

Core Safety Management Requirements for Export Hazardous Chemical Packaging (Focus on UN Closed-End Plastic Barrels)

1. Qualification certificates are mandatory; both certificates are indispensable

According to the "Regulations for the Implementation of the Law on Inspection of Import and Export Commodities" and the "Regulations on the Safety Management of Hazardous Chemicals," all UN1H1 closed-mouth plastic barrels used for exporting liquid hazardous chemicals must simultaneously hold two official documents:

Packaging Performance Test Result Sheet: UN closed-mouth plastic barrel manufacturers must submit samples to complete mandatory tests for airtightness, drop, stacking, and hydraulic. After passing, a performance certificate is obtained. Only closed barrels corresponding to model 1H1 can be used in hazardous chemical packaging, and only within the certificate validity period can they be recorded;

Packaging usage appraisal result form: After completing hazardous chemical filling, the enterprise applies to the local customs for batch by batch on-site appraisal. Customs officers verify the integrity of the barrel, UN mark, filling volume, sealing gasket, and hazard disclosure label. Only after passing the assessment can customs declaration and export proceed. If any documents are missing, customs will directly return or seal the goods.

2. UN1H1 Mandatory Identification Specification for Closed-Mouth Plastic Barrel Body Labeling

The 2026 new regulations tighten labeling controls. All sticker-type UN labels are invalid and must be cast and printed on the barrel body. The complete label includes six items: UN symbol, packaging code 1H1 (for closed-mouth plastic barrels), packaging grade X/Y/Z, MAXIMUM ALLOWABLE LOAD DENSITY, packaging production year, and country of manufacture code. It is strictly forbidden to mix 1H2 open barrel markings, alter or overwrite UN parameters, or use UN barrels that do not match the hazardous category level of the goods.

3. Physical Performance and Adaptation Safety Management

Material compatibility: UN closed-mouth plastic barrel raw materials must withstand corrosion from corresponding hazardous chemicals, with no added recycled materials. For volatile hazardous chemicals, UV resistance and anti-seepage additives must be added to prevent chemical leakage;

Three mandatory test baselines: no leakage after dropping at 1.2 meters (Y grade) or 1.8 meters (X grade), no leakage at 20kPa airtight for 5 minutes, and no deformation after stacking in a 40°C environment for 28 days;

Filling control: The loaded liquid must not exceed the density limits indicated by the UN label, with a safe expansion space reserved. The sealing ring and lid sealing structure must be intact, with no cracks, aging, or damage.

4. Key supervision items for on-site port inspections

Customs nationwide increased the inspection rate of UN closed-mouth plastic barrels to over 30%, focusing on four types of violations: discrepancies between UN labels and identification documents, deformed barrels with damaged seals and failures, unauthorized export declarations without two certificates, and ordinary, uncertified plastic barrels replacing UN closed-mouth barrels for transporting hazardous chemicals. In addition to rectifying goods seizures, violating enterprises will face administrative penalties of up to 200,000 yuan, and related dishonesty information will be entered into the import and export enterprise's credit files.

Customs policy interpretation

Customs regulatory staff explained that the new regulatory rules align with the United Nations "Recommendation on the Transport of Dangerous Goods" and the International Maritime IMDG Rules. The 1H1 UN closed-mouth plastic barrel, with its fully sealed structure and stable corrosion resistance, has become a standardized compliant container for cross-border transport of liquid flammable, corrosive, and toxic hazardous chemicals. In previous years, many companies exported uncertified ordinary plastic barrels or refurbished barrels due to cost-conscious use, making it easy for leaks to occur in the high-temperature and turbulent environment of ocean shipping, leading to ship pollution and fire and explosion safety incidents. Therefore, by 2026, packaging entry thresholds will be fully tightened to prevent safety risks in cross-border hazardous chemical transportation from the source.

Customs reminds all export enterprises to ensure that the plastic containers loaded with liquid hazardous chemicals are genuine UN1H1 closed-mouth certified barrels before export, complete both performance and usage packaging assessments in advance, keep the certificates intact for inspection, and ensure that the UN mark on the barrel body matches the hazardous characteristics of the goods. This eliminates violations such as misuse of labels, substandard goods as premium, and false concealment, ensuring smooth customs clearance and avoiding safety and economic losses.

Legal basis

Article 29 of the Implementation Regulations of the Law of the People's Republic of China on the Inspection of Import and Export Commodities

Articles 32 and 101 of the Regulations on the Safety Management of Hazardous Chemicals

SN/T 0370.2-2021 "Inspection Procedures for Export Dangerous Goods Packaging—Performance Inspection", SN/T 0370.3-2021 "Usage Appraisal"

United Nations Recommendations on the Transport of Dangerous Goods, IMDG Code 42-24 International Maritime Hazardous Regulations