Shanghai Customs of China Announced the Continuing Optimized Inspection Process of Imported Clothing Products

Oct. 16 2020

Shanghai Customs of the People's Republic of China had made the Shanghai Customs announcement order number 5 of 2020 on how to further optimize the inspection process of imported clothing products  on October 9, 2020. In order to carry out the measures of the General Administration of Customs on stabilizing foreign trade and foreign investment, promoting the quality of foreign trade steadily, optimizing the business environment at Shanghai ports, and promoting trade facilitation in accordance with the Customs Law of the People's Republic of China, the Import and Export Commodity Inspection Law of the People's Republic of China and its implementing regulations and other relevant provisions, the Shanghai Customs decided to optimize the import clothing inspection process in this customs port area. The relevant matters are hereby announced as follows.

1. To implement the safety risk assessment of imported clothing, Shanghai Customs carries out risk evaluation in accordance with the inspection and risk assessment of imported clothing products, combined with the credentials of customs enterprises, and dynamically adjust the mode of the conformity assessment procedures used for imported clothing based upon the evaluation results.

2. When an imported clothing is picked for inspection, the importing enterprise may apply to the Customs for a safety risk assessment of imported clothing and submit relevant information under the following circumstances:
i. With test reports issued by third-party testing institutes or enterprise’s own test reports, the enterprise may submit to the on-site customs the Declaration of Conformity of Imported Clothing (hereinafter referred to as the "Declaration of Conformity") (Annex 1), the test reports and the relevant accompanying information.
ii. For imported clothing that is not sold in the domestic market, such as for enterprise own use, sample display, research and development testing, tournament activities, new released products, etc., the enterprise may submit to the on-site customs Special Situation Explanatory Notes on Imported Clothing (hereinafter referred to as "Special Explanatory Notes") (Annex 2) and the relevant accompanying information.

3. Third-party test reports or enterprises’ own test reports submitted by enterprises should meet the following requirements:
i. Third-party test reports should meet the following requirements:
a) The testing institute has obtained the qualification of the import and export commodity testing and inspection institution and the accreditation from China National Accreditation Service for Conformity Assessment (CNAS) and the China Metrology Accreditation (CMA), and the relevant qualification and certification scope covers all the parameters involved in the imported clothing inspection.
b) Reports are listed with the test standards, testing methods and specific result values. The testing items shall include all applicable parameters under GB 18401 and GB 31701.
c) The test reports include elements that confirm the consistency between the inspected samples and the actual imported goods.
d) Reports from overseas testing and inspection agencies shall be evaluated at the discretion of Shanghai Customs.
ii.   Enterprises’ own test reports should meet the following requirements.
a)   Reports are listed with the test standards, testing methods and specific result values. The testing items shall include all applicable parameters under GB 18401 and GB 31701.
b)   Accompanying with its own laboratory introduction and explanatory notice of being independent from the associated enterprise for enabling to release objective test results.
c)   Description of any relevant testing qualifications, such as ILAC-MRA accreditation by a recognized accreditation agencies.
d)   The test reports include elements that confirm the consistency between the inspected samples and the actual imported goods

4. Shanghai Customs conducts safety risk assessment of imported clothing in accordance with regulations.
For imported clothing that has been qualified after risk assessment, the Customs shall complete the conformity assessment procedure in accordance with the relevant measures under the regulations.

Under the following circumstances, the risk assessment is regarded as not qualified, this batch of imported clothing is subject to conformity assessment procedures through sampling inspection:
i.   The enterprise fails to submit a Declaration of Conformity or Special Explanatory Notes.
ii.   The Declaration of Conformity, Special Explanatory Notes and relevant test reports submitted by the enterprise do not meet the requirements.
iii.   Ordered for inspection under the instruction initiated by the General Administration of Customs due to non-conformity warning notification or other reasons.
iv.   Other reasons that are not applicable to conformity assessment, conformity assurance and other conformity assessment procedures.

5. If the safety risk assessment of imported clothing is completed and the evaluated result as qualified, the importing enterprise may apply to the on-site customs for the return of picked samples with the "picking/sampling certificate" issued by the customs.

6. If you have any questions, you can contact Shanghai Customs for advice.

7. This announcement shall be implemented as of the date of publication.

Source: http://www.customs.gov.cn/shanghai_customs/423405/qtzhxx1/423461/423462/3310494/index.html
Annex 1: http://www.customs.gov.cn/shanghai_customs/423405/qtzhxx1/423461/423462/3310494/2020100915500435225.doc
Annex 2: http://www.customs.gov.cn/shanghai_customs/423405/qtzhxx1/423461/423462/3310494/2020100915502217362.doc

Commentary
This optimized inspection process does not mean Shanghai Customs would accept third-party test reports or enterprise’s own reports in lieu of performing the official inspection. Rather Shanghai Customs would take into consideration of qualified test reports, supporting documents and Declaration of Conformity provided by the importing enterprises, then evaluate and assess for whether performing conformity assessment procedures through sampling inspection, of which often involving destructive sample testing. When the risk assessment is evaluated as qualified, the importing enterprise may apply to the on-sites customs for returning the picked samples. This new optimized procedure is particularly beneficial to shipments going through Shanghai ports, with situations where the imported clothing products are with higher market value, such as luxury clothing, or when the overall shipment size is relatively small.

Another positive feature of this optimized process is to clarify the procedure of importing small number of clothing products that are not intended to be sold in China market, such as tailor-made staff uniform, tailor-made clothing for tournaments, marketing displayed samples, etc.

Bureau Veritas has numerous laboratories in China that are accredited with CNAS and CMA. If you would like to know more on how this might have impact on your business, please contact your Bureau Veritas customer service representative.

How Does this Impact You? Contact Us to Discuss
Please contact your Bureau Veritas customer service representative or email: info@us.bureauveritas.com.
China – Guangzhou: bvcps_pyinfo@cn.bureauveritas.com
China – Shanghai: contact-cn@bureauveritas.com

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