How to Classify Ink Exports? Which Are Considered Hazardous Materials?

According to the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), ink exports must be classified by composition:

• Solvent-based inks: Flash point ≤60°C must be transported as Class 3 hazardous materials (UN1263)
• Water-based inks: Typically treated as general cargo, but pH≤2 or ≥12.5 requires hazardous material declaration
• UV-curable inks: Containing photoinitiators may involve Class 9 hazardous materials (UN3082)

In 2025, the EU updated the EN ISO 21301 standard, requiring all ink exporters to provideprecise component percentages to 0.1%in SDS documents.

What International Certifications Are Required for Ink Exports?

Certification requirements vary significantly across different markets:

• European Union Market:
  • REACH Regulation (SVHC List Updated to 258 Items)
  • Packaging Directive 94/62/EC (Heavy Metal Content Testing)
• North American Market:
  • FDA 21 CFR 175.300 (Food Contact Materials)
  • California Proposition 65 (Heavy Metals and Phthalates Testing)
• Southeast Asian Market:
  • Indonesian SNI 06-1029-1989 Standard
  • Vietnamese Circular 04/2012/TT-BKHCN

What are the special requirements for ink transportation?

Dangerous goods transportation must comply with the new IMDG Code (2025 Edition) regulations:

• Packaging specifications: UN-certified packaging + triple leak-proof design
• Document Preparation:
  • MSDS must include GHS Revision 9 elements
  • Dangerous Goods Declaration (DGD) must indicate UN number
• Storage Conditions: Temperature should be maintained at 15-25℃ (some photosensitive inks require light protection)

How to correctly declare ink HS codes?

2025 Customs Commodity Classification Key Points:

• Printing Inks: 3215.1900 (Other Printing Inks)
• Writing Inks: 3215.9010 (ChinaExport DrawbackVAT rate 13%)
• Special Functional InksNeed to provideComposition Test ReportandPurpose Description

Note: U.S. Customs requires ink HS codes to match TSCA certification documents, while Japan requires labeling withJIS K5701standard number.

Key indicators for selecting inks?Export RepresentationProfessional agency services should possess:

Dangerous goods operation qualifications

• Hazardous materials operation qualificationIncluding DGSP certification and IATA qualifications
• Chemical customs clearance records≥50 export cases of similar products in the past 3 years
• Emergency handling capacityOverseas port hazardous chemical accident handling channels
• Compliance guarantee systemDual-person verification system + SDS automatic update system

a full - process cost listSimulated customs clearance test report, especially for sensitive markets such as India and the Middle East.

What are the new regulations for ink exports in 2025?

• China Customs has newly addedVolatile Organic Compounds (VOC) content declarationRequirements
• EU implementationCarbon Border Adjustment Mechanism (CBAM), ink production carbon emissions need to be traceable
• U.S. Customs launchesMandatory electronic labeling system(RFID traceability system)
• RCEP member states implementUnified chemical safety cardcertificate of tax residence