European Compliance Upgrade!

Foreign trade enterprises exporting to the European Union no longer only need to focus on a single transportation regulation. The EU Green Environmental Protection Act is deeply intertwined with dangerous goods safety rules, and even a slight negligence can lead to pitfalls in transportation and customs clearance. On August 12th, the European Union officially clarified the priority determination of PPWR packaging waste regulations and ADR road dangerous goods transportation regulations, which solves the long-standing practical problem in the industry: when there is a conflict between environmental packaging requirements and dangerous goods transportation safety requirements, dangerous goods transportation regulations have priority enforcement effect.

Many factories, in response to PPWR's requirements for recyclability and plastic reduction, directly replace lightweight and environmentally friendly packaging, while ignoring the rigid standards of UN hazardous packaging for box strength, leak resistance, and crush resistance. Some lithium batteries and fine chemical goods meet the environmental recycling standards for packaging, but do not meet the safety conditions for dangerous goods transportation, and were directly detained during inspections on EU inland roads. Once detained, the accompanying demurrage fees, inspection fees, and disposal costs of goods will also disrupt the overall pace of overseas delivery. For exporters, packaging selection cannot blindly pursue environmental indicators, and must balance environmental compliance with hazardous packaging safety.

Following the update of packaging policies, the Rotterdam Convention PIC prior informed consent list has been updated, and substances such as bisphenol A (BPA), NMP, DMF, cobalt salts, borates, etc. have been officially included in the control list. This type of chemical raw material is widely used in lithium battery slurries, coatings, polymer plastics, and electronic chemical materials. According to the rules, goods containing the above-mentioned controlled substances sent to the European Union must complete the PIC notification process in advance. Goods that have not completed the declaration will be refused entry.

At present, many domestic manufacturing companies are still focused on REACH registration of their products, ignoring the expansion of the PIC list. They only discover the lack of corresponding notification materials when the goods arrive at the port, causing unnecessary losses. It is recommended that relevant enterprises verify the chemical composition of their products in advance, improve their declaration materials, and prioritize compliance work before production booking.

The field of air transport of dangerous goods is also undergoing significant changes, with IATA releasing the 68th edition of DGR regulations, which will be enforced in January 2027. The new version specifically adds an independent UN number UN3564 for sodium ion batteries, supplements the identification clause for mixed lithium sodium batteries, and tightens the quantity limit for spare lithium batteries and power banks shipped by air.

At present, more and more sodium battery samples are being shipped by air in China, and many companies still use the UN number of traditional lithium-ion batteries for booking and declaration. Although there is still a transitional period, the old declaration methods will be completely invalidated after the new regulations come into effect. Enterprises should complete the classification and identification of goods as soon as possible, update document templates, and prepare for subsequent sample testing and bulk export.

In the second half of the year, the European and American Black Friday and Christmas stocking windows will open, and the proportion of dangerous goods inspections at various ports will increase synchronously. The compliance of dangerous goods exports runs through the entire process of domestic packaging, international transportation, and destination port customs clearance. Any errors in packaging, classification, and ingredient declaration can bring chain risks.

For chemical and new energy foreign trade practitioners, EU regulation is upgrading towards the dual dimensions of "environmental protection+safety". The policy update iteration speed is fast, and relying on old experience to ship is no longer reliable. Enterprises need to establish regular regulatory tracking, conduct self inspection and verification before shipment, and update packaging and declaration materials in a timely manner to cope with the continuously changing overseas regulatory environment.

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