Guidelines for the Declaration of Containers Carrying New Energy Vehicles on Inbound and Outbound Ships

Issued by the Maritime Safety Administration of the Ministry of Transport on November 22, 2025, these Guidelines represent a key regulatory document amid the sustained growth of China's new energy vehicle (NEV) exports. Data shows that in 2024, China's NEV exports reached 12 million units, a year-on-year increase of 35%, with maritime transportation accounting for over 90%. Will the new rules address the pain points of cumbersome declaration procedures and inconsistent standards for enterprises? And how will they impact the efficiency of NEV exports?

Which NEVs Require Declaration?

The Guidelines clearly define the scope of application: purely electric vehicles powered solely by lithium/sodium-ion batteries, or hybrid electric vehicles driven by internal combustion engines combined with lithium/sodium-ion batteries. These vehicles are generally classified as Class 9 dangerous goods under the International Maritime Dangerous Goods Code (IMDG Code), with UN numbers UN3171 (Battery-powered vehicles) or UN3496 (Fuel cell vehicles).

Notably, certain NEVs meeting exemption criteria may be exempt from dangerous goods management. For example, small electric vehicles with on-board storage batteries rated at no more than 100Wh, or vehicles that are fully discharged and in a stable state, may qualify for exemptions. Enterprises must carefully verify the specific exemption standards in the Guidelines to avoid over-declaration or under-declaration.

 

Required Declaration Documents

The declaration process consists of two main phases: "Ship Declaration" and "Cargo Declaration", for which enterprises need to submit different documents respectively:

Ship Declaration (for permission to carry dangerous goods on inbound/outbound ships)

Declaration Form for Ships Carrying Dangerous Goods

Ship's Fitness for Carriage Certificate or supporting documents

Proof of operational qualifications of the intended berthing port, terminal, and berth

Supporting documents for fixed routes and cargo (if applicable for periodic declarations)

Cargo Declaration (Dangerous Goods Safety and Fitness for Transport Report)

Dangerous Goods Safety and Fitness for Transport Declaration

Material Safety Data Sheet (MSDS)

Container Packing Certificate

Power of Attorney and copies of identification documents of both parties (if declaring through an agent)

Enterprises must pay special attention to ensuring consistency of information across all documents, especially key elements such as cargo name, UN number, and packing group. The Container Packing Certificate must be signed by a qualified packer to ensure compliance with international standards during loading.

 

Declaration Procedures

The Guidelines recommend two declaration methods, allowing enterprises to choose based on actual needs:

Online Application (Recommended)

Logging into the "Maritime One-Stop Service Platform" (https://zwfw.msa.gov.cn) is the most convenient option. Carriers or their agents must submit the "Ship Declaration" 24 hours before the ship's scheduled inbound/outbound voyage, while shippers or their agents should complete the "Cargo Declaration" before delivering the goods for transportation. The system will provide review results within 12 hours, enabling enterprises to check progress and download certificates online.

On-site Application

Submit paper documents at the service hall of the local maritime administrative agency. It is advisable to make an appointment in advance via phone or the "Haishi Tong" APP to avoid long waits. During on-site processing, staff will conduct preliminary document reviews, allowing for on-the-spot corrections of issues to improve the one-time approval rate.

Regardless of the application method, enterprises must adhere to declaration time limits. Failure to declare within the specified timeframe may result in ship delays and additional costs. For regular routes, enterprises are encouraged to apply for periodic declarations, which are valid for up to 30 days, significantly reducing repetitive declaration work.

 

Six Convenience Measures to Save Time and Effort

The six convenience measures introduced in the Guidelines are expected to reduce enterprises' declaration time by over 30%:

No Duplicate Submission: Enterprises are not required to re-submit documents proving port/terminal dangerous goods operational qualifications if such information is already available to local maritime authorities through information sharing. This measure reduces enterprises' document preparation workload by nearly 20%.

Exemption from Container Packing Certificate: NEVs transported in fixed flat racks/frame containers are exempt from submitting the Container Packing Certificate. This measure particularly benefits roll-on/roll-off shipping enterprises by simplifying the declaration process for full-ship shipments.

Transit Declaration Exemption: Containers carrying NEVs in transit through a port only need to declare "transit" upon entry, with no requirement for re-declaration upon exit. Enterprises at international transit hubs such as Shanghai Port and Shenzhen Port will directly benefit.

Transshipment Declaration Exemption: For NEV containers undergoing "water-water transshipment", after declaring "transshipment" on the first voyage, no additional "Cargo Declaration" is required for the second voyage. This will accelerate multimodal transport efficiency in regions such as the Yangtze River Economic Belt and the Pearl River Delta.

Periodic Declarations: Ships operating on relatively fixed routes and carrying only NEV containers may apply for periodic ship declarations valid for up to 30 days. Large shipping enterprises such as COSCO SHIPPING and Sinotrans will significantly reduce declaration frequency.

Cross-regional Acceptance: Pilot units for rail-sea intermodal transport may complete the "Cargo Declaration" at the place of origin, with no need for re-declaration at the loading port. This measure promotes the development of "railway + maritime" multimodal transport, particularly benefiting NEV exports from central and western regions.

 

Transition Period Preparation and Consultation Channels

After the implementation of the Guidelines, enterprises must familiarize themselves with the new requirements promptly. In particular, starting from January 1, 2026, the revised IMDG Code will adjust the classification and numbering of NEVs. Enterprises should communicate in advance with maritime authorities to ensure a smooth transition.

For inquiries, enterprises can seek assistance through the following channels:

National Maritime Service Hotline: 4008012395 (7:00-22:00)

Consultation hotlines of local maritime administrative agencies (available on the "Maritime One-Stop Service Platform")

Online consultation via the "Haishi Tong" APP (supports text-image communication and document pre-review)

 

NEV exports have become a new engine for China's foreign trade growth. Standardizing declaration procedures and improving customs clearance efficiency will further enhance the international competitiveness of "Made in China". Enterprises should fully leverage the convenience measures brought by the new rules while strengthening internal training to ensure compliant and efficient declaration work. With the popularization of digital declarations, the future goal of "one declaration, nationwide access" is expected to be achieved, paving the way for NEVs to enter global markets.

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