End-to-End Identification and Declaration Process for Hazardous Goods Exported to the United States

Phase 1: Pre-Export Product Identification and Classification

Prior to shipment, the accurate identification and classification of dangerous goods must be completed; this forms the foundation for all subsequent operations.

Entrust a professional appraisal : Testing of the product must be entrusted to a qualified, professional laboratory or institution. Self-assessment based solely on experience or the product name is not acceptable.

Identify key information : Based on the test results, the certification body will determine the following core information in accordance with the United Nations Model Regulations on the Transport of Dangerous Goods and the U.S. Department of Transportation (DOT) regulations (49 CFR):

UN Number : Such as UN1263 (paints).

Proper Shipping Name : The standard names prescribed by regulations must be used.

Hazard Category : Such as Class 3 (Flammable Liquids), Class 8 (Corrosives), etc.

Packaging Level : Levels I, II, or III indicate the degree of hazard.

Packaging Group : Determine the required performance level of the packaging.

Issue an appraisal report : Obtain the Certificate of Cargo Transport Conditions or the Safety Data Sheet (SDS). These documents will serve as critical supporting evidence for subsequent declarations and transportation.

Phase 2: Compliance Packaging and Labeling

Dangerous goods must be packaged in accordance with international and U.S. standards and properly labeled.

Use UN-certified packaging : Packaging containers must be certified by the United Nations. The packaging must bear a clear, durable UN marking to demonstrate that it has passed the relevant performance tests. For bulk shipments, a “Certificate of Use for Dangerous Goods Packaging Containers” (Dangerous Goods Packaging Certificate) issued by the manufacturer is typically required.

Affix hazardous materials labels : The outer packaging must be affixed with regulatory-compliant hazardous materials labels, including:

Hazard category labels (e.g., flammable liquids, corrosives symbols).

UN number label.

Directional label (if applicable for liquid packaging).

Depending on the product characteristics, additional special markings such as “Marine Pollutant” may also be required.

Provide a Safety Data Sheet : An SDS must contain 16 mandatory items of information, including product composition, physicochemical properties, fire-fighting measures, spill emergency response procedures, and transportation information, and serves as an essential document for transport, storage, and emergency response.

Phase 3: Domestic Export Declaration

Complete domestic export customs clearance procedures and declare to Chinese Customs.

Enterprise Qualification Preparation Export enterprises are required to obtain a series of qualifications, including the License for the Operation of Hazardous Chemicals, customs registration, and registration with the Inspection and Quarantine Bureau.

Prepare customs declaration documents : Includes standard documents such as the commercial invoice, packing list, contract, and power of attorney for customs brokerage.

Submit Special Documents : During customs declaration, the “Certificate of Inspection for the Use of Packaging for the Transport of Dangerous Goods for Export” (commonly referred to as the “Dangerous Goods Packaging Certificate”) and the “Certificate of Assessment of Cargo Transport Conditions,” among other documents, must be submitted to customs to demonstrate that both the packaging and the cargo comply with safety requirements for transport.

Cooperate with customs inspection : Customs may inspect dangerous goods to verify that the name, labels, packaging, and other details match the declaration. Upon successful verification, Customs will release the shipment.

Phase Four: U.S. Import Declaration and Compliance

The U.S.-side import declaration process must be initiated prior to the arrival of the goods at a U.S. port to comply with the requirements of U.S. Customs and Border Protection (CBP) and Partner Government Agencies (PGAs).

Declare to CBP and submit the “Entry Summary” The importer of the goods or their agent must submit an electronic import filing—known as the “Entry Summary”—through the U.S. Customs and Border Protection system. This is a mandatory step to initiate the customs clearance process.

Submit a TSCA Declaration For most chemical substances, importers are required to submit a Toxic Substances Control Act (TSCA) Declaration to CBP, certifying that the chemical either complies with all applicable TSCA regulations or is not subject to TSCA jurisdiction. This declaration must be printed on the commercial invoice or entry documentation.

Prepare standard customs clearance documents. : Provide a detailed commercial invoice, original bill of lading, and packing list; all document information must be in full compliance with the dangerous goods declaration.

Responding to the PGA Review In addition to CBP, other federal agencies may also regulate the import of hazardous materials. For example, the U.S. Environmental Protection Agency (EPA) oversees the composition and registration of chemicals, while the U.S. Consumer Product Safety Commission (CPSC) focuses on the labeling and safety of consumer products. Importers must ensure in advance that their products comply with the specific requirements of these agencies.

Payment of Customs Duties and Fees : Determine the tariff rate based on the product’s customs tariff code (e.g., chemicals in Chapters 28–29) and pay the applicable duties and related port charges on time.

Phase 5: Special Requirements for the Transportation Stage

In maritime or land transportation, shippers and carriers must also comply with additional safety regulations.

Submit a dangerous goods declaration to the carrier. : Submit a Dangerous Goods Declaration (DGD) to the shipping or airline company, providing detailed information such as the UN number, class, and packing group of the cargo, and attach a signed Dangerous Goods Declaration.

Carrier Registration and Filing : Depending on the volume of shipments and the types of hazardous materials, carriers may be required to register with the Ministry of Transport and pay applicable fees. For example, registration is mandatory when transporting explosives, highly toxic inhalation substances, or large quantities of dangerous goods exceeding specified thresholds. According to the regulations, the annual registration fee is US$250 to US$3,000 Between.

Driver Background Check : When transporting certain hazardous materials into the United States by road from Canada or Mexico, drivers must hold a Free and Secure Trade (FAST) card or a Transportation Worker Identification Credential (TWIC) to demonstrate that they have undergone a security background check.

Important Notes

Strict Compliance and Prohibition of Concealment : Concealing, misreporting, or failing to report the hazardous nature of dangerous goods is an extremely serious offense, subject to substantial fines, criminal prosecution, and potential inclusion on industry blacklists.

Permit for Specific Controlled Substances : If the exported goods are precursor chemicals or pharmaceuticals subject to regulation under the Controlled Substances Act, an import license must be obtained in advance from the U.S. Drug Enforcement Administration (DEA) or the relevant authority; otherwise, entry will be prohibited.

Regulatory Updates : U.S. regulations on hazardous materials and tariff policies are frequently updated. For example, effective November 10, 2025, China will designate the United States as a “specific country” for the export of new precursor chemicals, requiring official export licenses for relevant items. Shippers must closely monitor regulatory changes to ensure ongoing compliance.

Choose a Professional Partner : The export process for dangerous goods is complex; it is strongly recommended to engage a freight forwarder and customs broker with extensive experience in handling dangerous goods and a thorough understanding of U.S. regulations to mitigate potential risks.