When exported cosmetics are classified as dangerous goods during the return process (Flammable Liquids / Special Provision A58)
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After exporting hair toner overseas, we decided to re-import it due to sluggish sales. During this process, it was classified as dangerous goods by the destination country, and the return is being continuously delayed due to issues with documentation and procedures.
1. The MSDS received from the domestic manufacturer classifies the product as non-dangerous goods. I am wondering if I should request the manufacturer to re-investigate this product. The alcohol content of the product is 23%.
2. I received the dangerous goods classification and related documents from the destination country. It states that because the flash point is 30°C, it is classified as Class 3 Flammable Liquid (UN NUMBER 1170, CLASS 3, PACKING GROUP III). We had recognized this as a general cosmetic product; I am wondering if this product is indeed supposed to be classified as dangerous goods, and whether it is treated as such due to the ethanol content or other specific conditions.
3. The destination country is requesting that we submit a revised MSDS. Until now, we have processed this as a general product for both domestic and other overseas exports. If we revise the MSDS, will we be required to manage and distribute it according to dangerous goods management regulations moving forward? I would appreciate it if you could advise me on which regulations I should be mindful of.
Answer 1
- 0First of all, the MSDS you provided does not contain sufficient information to determine whether the product is classified as dangerous goods. Therefore, it appears that the customs authorities of the destination country collected actual samples and conducted testing. As a result of the test, the flash point was confirmed to be 30°C, leading to the order to classify it as Class 3. In other words, even if it is a general cosmetic product, any flammable liquid with a flash point of 60°C or below is classified as dangerous goods. Thus, while it is correct that the item is classified as dangerous goods, under IATA DGR (Dangerous Goods Regulations) for air transport, aqueous solutions containing 24% or less alcohol can be classified as non-dangerous goods based on Special Provision A58. Since the MSDS you previously received cannot be considered a reliable source of information, a comprehensive revision of the MSDS seems inevitable after confirming with the shipper. In particular, when revising the MSDS, if the alcohol content is 24% or less, please declare in the remarks section of Section 14: "Not restricted as per Special Provision A58 that an aqueous solution containing 24% or less alcohol by volume is not subject to IATA DGR". This will allow you to ship it as non-dangerous goods based on Special Provision A58 after verifying with the airline for future exports.Machine translated
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