What should be noted in the export of medical oxygen?
2025-07-02
As we all know, oxygen is one of the most important gaseous substances on Earth. Animal respiration, combustion, and all oxidation processes (including the decay of organic matter) consume oxygen. As a vital medical resource, medical oxygen plays an extremely important role in saving patients' lives. Today, let's learn about the precautions for China's medical oxygen export.
PART 01 Properties of Oxygen
Oxygen is a monoatomic element formed by oxygen atoms, with the chemical formula O₂. It is a colorless, odorless gas and the most common monoatomic form of oxygen, exhibiting relatively active chemical properties. Oxygen is classified as a hazardous chemical and is considered dangerous goods during transportation.
Compressed or liquefied oxygen is listed as entry 2528 in the Catalog of Hazardous Chemicals (2015 Edition). Additionally, certain gas mixtures, such as a combination of oxygen (entry 2528 in the catalog) and carbon dioxide (entry 642 in the catalog) that are compressed or liquefied, should also be managed in accordance with hazardous chemicals regulations.
In accordance with the Regulations on the Safety Administration of Hazardous Chemicals (State Council Decree No. 591) and the requirements of the General Administration of Customs of China Announcement No. 129 of 2020, customs authorities conduct inspections on imported and exported hazardous chemicals listed in the latest edition of the national Catalog of Hazardous Chemicals.
PART 02 Pre-Export Preparations
01. Compliance Statement for Export of Hazardous Chemicals Manufacturing Enterprises;
02. Performance Inspection Result Certificate for Transport Packaging of Exit Goods;
03. Hazardous Properties Classification and Identification Report;
04. Samples of Hazard Communication Labels and Safety Data Sheets (if in foreign languages, corresponding Chinese translations shall be provided);
05. For products requiring the addition of inhibitors or stabilizers, a description of the actual names and quantities of inhibitors or stabilizers added shall be provided.
PART 03 Pre-Export Preparations
01. Commodity Classification:
In international trade, pure oxygen (excluding products with artificially altered isotopic composition) is generally classified under HS code 2804400000. Mixed gases containing oxygen (e.g., oxygen mixed with carbon dioxide) are typically classified under HS code 3824999999.
02. Export Tax Rebates:
The export tax rebate rate for pure oxygen (HS code 2804400000) is 0%. The export tax rebate rate for oxygen mixtures (HS code 3824999999) is 13%.
03. Export Regulatory Documents:
Pure oxygen requires an exit inspection and quarantine (electronic account) certificate (regulatory document code: B). No specific regulatory conditions apply to the export of oxygen mixtures.
PART 04 Export Transportation
In the United Nations Recommendations on the Transport of Dangerous Goods - Model Regulations, oxygen is classified under UN No. 1072 (compressed oxygen) and UN No. 1073 (refrigerated liquid oxygen). Limited and excepted quantities are not permitted for transport.
Important Reminder: Special provision 355 for compressed oxygen applies to oxygen cylinders for emergency use, which may include installed starting cartridges. If the total mass of propellant explosives per cylinder does not exceed 3.2 grams, the classification under Division 2.2 need not be changed. When transporting oxygen cylinders equipped with starting cartridges, effective measures must be taken to prevent accidental activation.
（一）Packaging Specifications for Sea Transportation
Pressure vessels filled with oxygen must comply with the following standards for design, construction, initial inspection, and testing:
For compressed oxygen (UN No. 1072):
01. The working pressure of the pressure vessel must not exceed two-thirds of its test pressure. Under no circumstances shall the internal pressure at 65°C exceed the test pressure.
02. If aluminum alloy pressure vessels are used, they must be fitted with copper or stainless steel valves, cleaned in accordance with ISO 11621:1997, and free from oil contamination.
For refrigerated liquid oxygen (UN No. 1073):
01. Closed cryogenic vessels must be insulated to prevent frost formation on their external surfaces.
02. Minimum test pressure requirements:
(a) For closed cryogenic vessels with vacuum insulation, the test pressure must not be less than [maximum internal pressure of the vessel + 100 kPa (1 bar)] × 1.3 (the maximum internal pressure includes pressures during filling and discharge).
(b) For other closed cryogenic vessels, the test pressure must not be less than 1.3 times the maximum internal pressure of the vessel, taking into account pressure increases during filling and discharge.
03. Filling ratio: At the filling temperature and under 100 kPa (1 bar) pressure, the volume of liquid filled must not exceed 98% of the water capacity of the vessel.
04. Pressure relief devices: At least one pressure relief device must be installed, and periodic inspections and tests of pressure relief valves must be conducted at intervals not exceeding five years.
（二） Packaging Specifications for Air Transportation
The air transport of refrigerated liquid oxygen (UN No. 1073) requires prior approval from the authorities of the country of origin and the operator’s country (approval documents must include quantity restrictions, packaging requirements, and must accompany the shipment). Transportation by cargo aircraft is permitted only in accordance with the written conditions established by these authorities.
For compressed oxygen (UN No. 1072):
01. Cylinder test intervals may be 10 years. The working pressure must not exceed two-thirds of the cylinder test pressure. Under no circumstances shall the internal pressure at 65°C exceed the test pressure.
02. If aluminum alloy cylinders are used, they must be fitted with copper or stainless steel valves, cleaned in accordance with ISO 11621:1997, and free from oil contamination.
03. For passenger and cargo aircraft, the maximum net quantity per package is 75 kg; for cargo-only aircraft, the maximum net quantity per package is 150 kg.
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