(Coumarin Derivative Pesticides, Solid, Toxic) IATA DGR/ADR/IMDG: UN 3027, CLASS: 6.1 UN Codes “1A2/X” = Open-Steel-Drum/PG: I Transportation: By sea only, Full Container Load. GHS/EU CLP: Danger, GHS06, GHS09, GHS08. EU/China HS Code: 2932209013 (MOA & GAC)
5 active ingredients registered in China
As the pioneer of rodenticides in China, Siyang Rodenticide Factory had registered a total of 5 active ingredients of anticoagulant rodenticides with the MOA in the past decades. These include: (1) Chlorophacinone (sole registration in China, renewal stopped in 2000), (2) Warfarin and (3) Coumatetralyl (both terminated under the 2017 regulations), as well as (4) Brodifacoum and (5) Bromadiolone for the 2 rodenticides adopted to be national.
Siyang Rodenticide Factory is the only authorized exporter of Bromadiolone TC in China: certified classification of hazardous chemicals with reference to UN TDG (UN Recommendations on the Transport of Dangerous Goods – Model Regulations) as “UN 3027, CLASS 6.1, PG: I”, subject to GAC mandatory export inspection (former CIQ) and pesticide export release order issued by ICAMA based on the Rotterdam Convention with 10-digit tariff number “2932209013” as specified by the China regulations (Catalogue of the People’s Republic of China for the Administration of the Import and Export of Pesticides).
The licensed Bromadiolone TC from China
Bromadiolone, as a hazardous chemical, requires certification of hazard classification with reference to UN TDG for export from China. The technical material is certified as “UN 3027, Class 6.1, PG: I (Coumarin derivative pesticides, Solid, Toxic)”. At the same time, it is a mandatory GAC inspection (formerly CIQ) for export from China according to the regulations. And from the Internet, a common illegal that is changed UN 2811 (Toxic Solid, Organic, N.O.S.). – A sample of GAC inspection certificate submitted to shipowners according to IMDG Code and China SN/T 0370.3-2021 Regulations (Rules For the Inspection of Packaging for Export Dangerous Goods – Part 3: Use Appraisal).
Bromadiolone, as a registered pesticide, export from China is subject to ICAMA legal approval and the issuance of a release order. The commodity code for Bromadiolone technical material (TC) including its concentrate (TK) has been clarified by the “Catalogue of the People’s Republic of China for the Administration of the Import and Export of Pesticides” regulation jointly issued by the MOA and GAC as the 10-digit Chinese tariff number “293220-90-13″. And from the Internet, a common illegal that is changed 380899 HS Code (RB, ready for use). – A sample of ICAMA export release order submitted to the GAC (Customs) under the China Pesticide Regulations based on the exercise of the Rotterdam Convention duties.
Bromadiolone technical material is a highly toxic chemical, lethal in small doses, with a toxicity class of Ia (extremely hazardous) recommended by the WHO and classified as Class I (very toxic) by EU Directive 67/548/EEC (now CLP regulation). It is classified as a HyperToxic (Mandarin: jù dú) chemical of the highest control level according to the Chinese decrees of 2002 and 2015, and is not available for air transport in China. And ocean shipments for export can only be Full Container Load (FCL). – A basic lesson: the cost of transporting extremely dangerous goods by sea in LCL (Less than Container Load) is certainly much higher than in FCL.
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