Six shipping companies issue a declaration to enhance safety and prevent hazardous cargo misrepresentation in domestic container transport.
In a decisive move to uphold maritime safety standards and eliminate critical risks associated with the transportation of hazardous materials in containerised cargo, six domestic container shipping enterprises - Shanghai Pan Asia Shipping, Quanzhou Antong Logistics, Xinfeng (Ningbo) Shipping, Shanghai Zhonggu Logistics, Tangshan Port Hede Shipping, and Ningbo Ocean Shipping - have jointly issued a formal declaration. Anchored in the legal authority of the Maritime Law of the People's Republic of China, the Maritime Traffic Safety Law of the People's Republic of China, the Regulations on Domestic Waterway Transport Management, and the Safety Law on Hazardous Chemicals, the announcement signals a collective, industry-wide commitment to eradicating the concealment, misrepresentation, and illegal smuggling of dangerous goods in domestic container transport.
Under the terms of the declaration, shippers, freight forwarders, and all related parties are required to accurately declare the name, nature, and classification of all consigned cargo. The misrepresentation of hazardous materials - including dangerous chemicals, lithium batteries, and oxidising agents - as ordinary goods is strictly prohibited. Parties found to be in violation following formal investigation will be reported to the industry at large and incorporated into a shared information mechanism for hazardous goods concealment. Member enterprises of the joint declaration retain the right to suspend or refuse booking acceptance based on individual risk assessments, with reinstatement contingent upon full rectification and successful verification by the joint signatories. Where violations result in damage to vessels or port facilities, personal injury, or environmental contamination, responsible parties will bear corresponding administrative, civil, and criminal liability as prescribed by law.
The full text of the joint declaration is as follows:
I. The enterprises party to this joint declaration resolutely oppose all unlawful conduct by shippers, freight forwarders, and related parties - including the concealment or misrepresentation of hazardous goods and the illegal smuggling of dangerous cargo - in the course of domestic container freight transport.
II. Shippers, freight forwarders, and all related parties must ensure that all consigned cargo is declared accurately, including the correct name, nature, and classification of goods. The false or concealed declaration of dangerous chemicals, lithium batteries, oxidising agents, or any other hazardous materials as ordinary cargo for containerised shipment is strictly forbidden.
III. Where shippers, freight forwarders, or other responsible parties are confirmed, following investigation, to have concealed, misrepresented, or smuggled hazardous goods, the enterprises party to this joint declaration will issue formal industry notifications and incorporate such parties into the industry information-sharing mechanism for hazardous goods concealment. Each member enterprise will determine, on the basis of its own risk assessment, whether to accept bookings from such parties. Reinstatement will only follow the complete rectification of all violations, the elimination of safety hazards, and joint verification and approval by the signatory enterprises, after which a further industry notification will be issued.
IV. The application of industry-level constraints under this declaration does not preclude or diminish the administrative, civil, or criminal liability that responsible parties are required to bear under applicable law. All losses arising from vessel damage, port facility damage, personal injury, or environmental pollution caused by the concealment or smuggling of hazardous goods shall be borne in full by the responsible party.
V. Ports, cargo owners, and all members of the public are warmly encouraged to report instances of hazardous goods concealment, misrepresentation, or smuggling, in a collective effort to maintain the safety and integrity of domestic container shipping operations.
The challenge of hazardous goods misrepresentation in domestic container transport is equally prevalent in international container shipping - and, given the involvement of international routes, multi-jurisdictional customs authorities, and global maritime regulations, the compliance requirements and enforcement consequences in the international context are often considerably more stringent.
International container transport is governed by the International Maritime Dangerous Goods Code (IMDG Code), the International Convention for the Safety of Life at Sea (SOLAS), and the regulations of customs authorities, port administrations, and shipping lines across multiple jurisdictions. Dangerous chemicals, lithium batteries, fireworks, oxidising agents, flammable liquids, and other regulated cargo categories, if improperly declared, packaged, labelled, or transported, pose consequences in the event of an incident at a port, aboard a vessel, or in transit that far exceed those associated with ordinary cargo damage.
In recent years, major international shipping lines have substantially strengthened the rigour of their hazardous goods declaration review processes. ONE, for example, has established a contractual breach compensation mechanism under which confirmed post-inspection misrepresentation of hazardous goods may attract penalties of up to USD 30,000 per container. CMA CGM, Maersk, Hapag-Lloyd, and other leading carriers have similarly adopted measures ranging from substantial financial penalties and booking suspension to contract termination and blacklisting in response to false or concealed declarations. At the customs level, confirmed cases of hazardous goods misclassification may result in cargo detention, return, or destruction, with responsible parties additionally exposed to administrative sanctions and potential criminal liability.
For international freight forwarders and export enterprises, the following areas warrant particular attention:
- Verify the actual nature of the cargo independently; reliance solely on the product name provided by the shipper is insufficient.
- Confirm whether the goods constitute hazardous materials, and where necessary, require the shipper to provide a Material Safety Data Sheet (MSDS), a UN38.3 test report, and dangerous goods packaging certification.
- Ensure full consistency across booking documentation, customs declarations, bills of lading, and container packing information.
- Where a shipper demonstrates a tendency toward misrepresentation, proactively decline to accept the booking to avoid exposure to joint liability arising from facilitation of non-compliance.
The joint declaration issued by domestic container shipping enterprises sends an unambiguous signal of the industry's zero-tolerance stance toward hazardous goods misrepresentation. The same principle governs international container transport without exception - accurate, truthful declaration and fully compliant operational practice represent not only the fundamental requirement for safeguarding vessels, ports, and personnel, but also the inviolable baseline for freight forwarders and export enterprises seeking to manage legal risk and protect the long-term continuity of their operations.
