- CAS No.: 28772-56-7
EC No.: 249-205-9
Mol. Formula: C30H23BrO4
IUPAC: 3-[3-(4′-bromo[1,1′-biphenyl]-4-yl)-3-hydroxy-1-phenylpropyl]-4-hydroxy-2-benzopyrone
SDS (EU): Bromadiolone Technical Material
- (Coumarin Derivative Pesticides, Solid, Toxic)
IATA DGR/ADR/IMDG: UN 3027, CLASS: 6.1
UN Seal: 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)
Global Rodenticide Industry Highlights – Successfully developed 6 active ingredients, including Difenacoum, with 5 registrations in China’s MOA
- 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).
Siyang Rodenticide Factory is the only legal unit in China authorized by law to export Brodifacoum TC
– based on the 2015 Hazardous Chemicals Regulations & 2017 Pesticides Law.
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- 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.
- 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).
- A typical illegal export is the change from UN 3027 (Coumarin derivative pesticides, Solid, Toxic) to UN 2811 (toxic solids, organics, n.o.s.) for hazardous chemical substances, which is used to avoid regulation by Maritime Authorities.
- Bromadiolone, as a commodity 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 “2932209013“.
- 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.
- Another typical illegal export is the change of the legislated export commodity pesticide code 2932209013 (bromadiolone) to 380899 ****, the HS code for RB (0.005%, Ready-for-Use Baits), in order to circumvent the Customs Authorities.
- Bromadiolone technical material is a extremely toxic chemical, the highest controlled hazardous substance in China, 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.
Legal UN package marking for Brodifacoum TC and Bromadiolone TC
Simple to determine whether Bromadiolone TC (UN 3027) is legal to import & export:
1, first see whether the steel drum, followed by compliance with the United Nations marking above;
2, check whether to use the legal HS code (29322090-XX) for customs declaration and customs clearance.
