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09 March 2021 Oasis Circular No.: 2103 Subject: China Implements A

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09 March 2021 Oasis Circular No.: 2103 Subject: China Implements A Date: 09 March 2021 Oasis Circular No.: 2103 Subject: China implements a ban on the transportation of highly toxic chemicals in the Yangtze River basin from 01 Mar 2021 In order to strengthen the protection and restoration of the ecological environment, to promote the rational and efficient utilization of resources and ensure ecological safety in the Yangtze River Basin, China enacted the Yangtze River Protection Law (hereinafter referred to as the “Law”) on 26 Dec 2020 which came into effect as of 01 Mar 2021. The total length of the Yangtze River is about 6300 km and its the main waterway is about 2843 km long. The main ports along the Yangtze River include some wharfs of Shanghai Port in Yangtze River, Taicang, Changshu, Nantong, Jiangyin, Zhangjiagang, Jingjiang, Taizhou, Yangzhou, Zhenjiang, Nanjing, Ma An Shan , Wuhan, Yibin, etc. As per Art. 51 of the Law, “It is prohibited to transport highly toxic chemicals and other dangerous chemicals forbidden to be transported by inland river in the Yangtze River Basin.” As per Art. 90 of the Law, “Those who violate the provisions of this law, transport those highly toxic chemicals and other dangerous chemicals forbidden to be transported by inland river in the Yangtze River Basin, shall be ordered by the competent department of transportation or the MSA at or above the county level to correct their action, their illegal gains shall be confiscated and they shall be fined not less than CNY200,000 but not more than CNY 2.0 million, and the persons in charge and other directly responsible persons shall be fined not less than CNY 50,000 but not more than CNY 100,000. If the circumstances are serious, they shall be ordered to suspend their business for rectification or have their relevant business license revoked.” In order to implement the Law, Shanghai MSA issued a Notice on 18 Feb 2021 (see Annex I, hereafter referred as “Notice”) on the ban in the Shanghai section of Yangtze River , in which Shanghai MSA elaborated on the restriction of “Highly toxic chemicals” and “Other dangerous chemicals forbidden to be transported by inland river”. According to the Notice, the “Highly toxic chemicals” referred to in the Law are those chemicals marked as "highly toxic" in the remarks column of the Catalogue of Hazardous Chemicals (2015 Edition) formulated by the General Administration of Safety Supervision in conjunction with the Ministry of Industry and Information Technology (See Annex II). Regarding the “Other dangerous chemicals forbidden to be transported by inland river”, they are the chemicals listed in the Catalogue of Prohibited Dangerous Chemicals by Inland River ( 2019 Edition) formulated by the Ministry of Transport in conjunction with the Ministry of Ecological Environment (see Annex III). According to this Catalogue, 228 types of dangerous chemical cargo are totally forbidden to be transported by inland river regardless of its packing and the other 85 types of dangerous chemical cargo are forbidden to be transported by inland river in bulk. According to Shanghai MSA, the object of punishment mainly refers to the carrier who transports the prohibited goods in the Yangtze River in violation of the Law. However, if the carrier transports the goods without the knowledge of what is actually being transported because the shipper or the cargo owner falsely declares the prohibited goods, the MSA will also punish the shipper according to the regulations. Meanwhile, the Law is applicable to the export, import, transit and transfer of the aforesaid forbidden goods in the Yangtze River Basin. Suggestions Before accepting the booking of chemicals for shipment which will be transported in the Yangtze River Basin, Owners or carriers should take relevant measures to verify whether the shipment belongs to the Catalog mentioned above, including requesting the shipper/client to submit exact cargo information, customs code, UN No., CAS code, technical specification and relevant license of the shipment. If the nature of the chemical goods is not clear before transportation, the concerned party is suggested to appoint a qualified third‐party inspection institute for identification of the cargo or to liaise with the local MSA (via agent) to have the cargo verified. We hope the above is of assistance. Should you have any query, please feel free to contact us at any time. Best regards, Oasis P&I Services Company Limited Annex I ‐ Free translation of Notice of Shanghai MSA 2 pages Annex II ‐ Free translation of “Highly toxic chemicals” in the Catalogue of Hazardous Chemicals (2015 Edition) 11 pages Annex III ‐ Free translation of Catalogue of Prohibited Dangerous Chemicals by Inland River ( 2019 Edition) 38pages Annex I Notice of Shanghai MSA Re: Implementing the requirements of the Yangtze River Protection Law to prohibit the transportation of highly toxic chemicals and other goods in the Shanghai section of the Yangtze River To Relevant Parties: The Yangtze River Protection Law of the people's Republic of China (hereinafter referred to as the "Protection Law") which was approved in the 24th Meeting of the Standing Committee of the 13th National People's Congress on 26 December, 2020, will come into force on 01 March, 2021. The 2nd paragraph of Article 51 of the Law stipulates that "It is prohibited to transport highly toxic chemicals and other dangerous chemicals forbidden to be transported by inland river in the Yangtze River Basin". According to this article, the “highly toxic chemicals” and “other dangerous chemicals transported by inland river“ are the prohibited goods in the Yangtze River Basin. According to the 3rd paragraph of Article 54 of the Regulations on the Safety Management of Hazardous Chemicals, the "highly toxic chemicals" referred to in the Protection Law are the chemicals marked as "highly toxic" in the remarks column of the Catalogue of Hazardous Chemicals (2015 Edition) formulated by the General Administration of Safety Supervision in conjunction with the Ministry of Industry and Information Technology; the “Other dangerous chemicals transported by inland river” are the chemicals listed in the Catalogue of Prohibited Dangerous Chemicals by Inland River ( 2019 Edition) formulated by the Ministry of Transport in conjunction with the Ministry of Ecological Environment. According to Article 2 of the Protection Law, the Shanghai section of the Yangtze River belongs to the Yangtze River as specified in the Protection Law. From 01 March 2021, it shall be prohibited to enter/leave, transit or transfer the prohibited goods mentioned above, including transportation in bulk or in package by ship. In accordance with the provisions of Article 90, those who violate the provisions shall be ordered by the competent department of transportation or the MSA at or above the county level to correct their action, their illegal gains shall be confiscated and they shall be fined not less than CNY200,000 but not more than CNY 2.0 million, and the persons in charge and other directly responsible persons shall be fined not less than CNY 50,000 but not more than CNY 100,000. If the circumstances are serious, they shall be ordered to suspend their business for rectification, or have their relevant license revoked. In order to follow the requirements of the Protection Law, shipping enterprises in Shanghai port are requested to attach great importance to the above requirements. From 01 March 2021, it is strictly prohibited for ships to carry highly toxic substances and other dangerous chemicals forbidden to be transported by inland rivers to enter, transit and transfer in the Shanghai section of the Yangtze river. Notice is hereby given Shanghai MSA 18 February 2021 Annex II Catalogue of Dangerous Chemicals (2015 Edition) Highly toxic chemicals Definition: Chemicals with severe acute toxicity include synthetic chemicals, their mixtures and natural toxins, as well as chemicals with acute toxicity and easy to cause public safety hazards. Criteria for severe acute toxicity: Acute toxicity category 1, which meets one of the following conditions: In rats, oral LD50 ≤ 5mg / kg, percutaneous LD50 ≤ 50mg / kg, inhalation (4h) 3 LC50 ≤ 100ml / m (gas) or 0.5mg/l (steam) or 0.05mg/l (dust, fog). The experimental data of LD50 can also be used in rabbits. The meaning of each column in the catalogue of hazardous chemicals: 1. "Serial number" refers to the sequence number of chemicals in the catalogue of dangerous chemicals. 2. "Product name" refers to the name determined according to the Principles of Chemical Nomenclature (1980). 3. "Alias" refers to names other than "product name", including common name, popular name, etc. 4. "CAS No." refers to the unique registration number of chemicals by the United States Chemical Abstracts Service. 5. "Remarks" is a special note for highly toxic chemicals. Highly toxic chemicals of Catalogue of Dangerous Chemical Serial Product name Alias CAS No. Remarks No. 5‐amino‐3‐phenyl‐1 ‐[bis (N, 4 N‐dimethylamino‐oxophosphonyl)]‐1,2, Triamiphos 1031‐47‐6 Highly toxic 4‐triazole [content > 20] 20 3‐aminopropene Allyl amine 107‐11‐9 Highly toxic Perfluoroisobutylene;1,1,3,3 ‐ 40 Octafluoroisobutylene pentafluoro‐2 ‐(trifluoromethyl) 382‐21‐8 Highly toxic ‐1‐propene 41 Octamethylpyrophosphoramide (OMPA) Schradan 152‐16‐9 Highly toxic 1,3,4,5,6,7,8,8‐ocyclo‐1,3,3 a,4,7,7a‐ Octachlorhexahydroxyethyl 42 hexahydro‐4,7‐toluene furan [1%> 297‐78‐9 Highly toxic benzo‐furan; carbochlorine content] Thiophenol;Thiol benzene, 71 Phenyl mercaptan 108‐98‐5 Highly toxic mercaptobenzene Phenylarsine dichloride,
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