I. Does tar export require special qualifications?

According to the latest 2025 DangerousChemicalsGoods List, coal tar (HS Code 2708) belongs toClass 9 dangerous goods.Agency export,Must meet three core requirements:

• Production enterprises must hold Hazardous Chemicals Registration Certificate
• Exporters must possess Hazardous Chemicals Business License
• Pass dangerous goods transport identification (requires UN38.3 test report)

II. Typical penalty scenarios for customs-seized tar

According to publicly disclosed cases by the General Administration of Customs in recent three years, main penalty types include:

• False declaration penalties
  • Failure to declare hazardous properties: 10-30% of goods value as fine
  • HS Code classification errors: 1-3 times of evaded taxes as fine
• Qualification deficiency penalties
  • No hazardous chemicals export license: confiscation of goods plus fines
  • Non-compliant transport conditions: maximum fine of 500,000 yuan
• Repeated violation escalation penalties
  • Three similar violations within one year will suspend export qualification
  • Cases involving smuggling will be transferred for criminal investigation

III. Response suggestions after goods seizure

Recommended steps for handling customs seizure incidents:

• Immediately stop related trade processes
• Commission professionalcustoms clearancecompany to conductsituation pre-assessment analysis
• Prepare three types of supporting documents:
  • Hazardous chemicals qualification documents from production enterprises
  • Complete Material Safety Data Sheet (MSDS)
  • Compliance certificates issued by third-party testing agencies
• Apply for hearing within 7 days after receiving Administrative Penalty Notice

IV. How to establish compliant export procedures?

Recommended implementation of four-step risk control system:

• Preliminary reviewVerify 13 qualifications including the manufacturers Pollutant Discharge Permit
• Declaration verificationConfirm HS code through customs pre-classification system
• Transportation controlUse registered dangerous goods transport vehicles
• 32. Document managementRetain complete trade documents for at least 5 years

V. Do agency companies bear joint liability?

According to Article 929 of the Civil Code, two scenarios need to be distinguished:

• If the agency company fulfillsreasonable review obligationsthe principal shall be liable in principle
• If there existsknowingly acting as agent in violation of regulationsjoint liability for compensation shall be borne

A 2024 typical case showed that because the agency company failed to verify hazardous chemicals transport qualifications, it ultimately bore 42% of the penalty share.

VI. How to apply for administrative penalty reduction or exemption?

The following conditions may qualify for mitigated penalties:

• First-time violation with minor harmful consequences
• Voluntarily eliminating or mitigating the consequences of illegal acts
• Cooperating with customs investigation and providing key evidence

It is recommended to apply for administrative reconsideration within 60 days of receiving the Administrative Penalty Decision, or file an administrative lawsuit within 6 months.

VII. Latest regulatory trends for tar exports

In 2025, the General Administration of Customs will strengthen three supervision measures:

• ImplementationIntelligent supervision system for hazardous chemicals
• EstablishedExport enterprise credit blacklist system
• ConductCustoms-enterprise joint compliance training program

It is recommended that enterprises log in to the "China International Trade Single Window" every quarter to check for updates on regulatory dynamics.