Powder Actuated Cartridge Export from China: Complete Compliance Guide 2026
171,500 Cartridges Seized at Ningbo Port
June 2026, Ningbo Beilun. A container declared as "fasteners" was opened. Inside: 171,500 powder actuated cartridges — Class 1 explosives disguised as hardware. Same month, same customs district, another 40,000 cartridges were intercepted, declared as "flashlights and nail guns."
For exporters, powder actuated cartridge export compliance is not optional. This guide covers the full regulatory framework — from China's domestic legal exemptions to international IMDG Code requirements.
1. The Three-Layer Regulatory Framework
PAC compliance operates across three distinct layers of regulation:
1.1 International: IMDG Code
Under the IMDG Code (Amendment 42-24), PACs are classified as UN 0323 / CARTRIDGES, POWER DEVICE, Class 1.4S (Explosives, Compatibility Group S). For the full classification overview, see our DG classification guide.
Special Provision 347: Cartridges must pass UN Manual of Tests and Criteria Part I, Test Series 6(d), demonstrating hazardous effects remain confined within the package. Products failing SP 347 do not qualify as 1.4S.
1.2 National: China's Security Standards + Civil Explosives Exemption
| Regulation | Status | Key Provisions |
|---|---|---|
| GA 1525-2018 | Mandatory (MPS) Effective 2019-05-01 | Public security technical requirements; anti-tampering |
| GB/T 19914-2005 | Recommended (superseded) | Manufacturing, testing, packaging, transport, storage |
| Civil Explosives Safety Regulations | State Council Decree | Art. 2: Applies only to items listed in the catalogue. PACs are NOT listed — these regulations do NOT apply. |
| Civil Explosives Catalogue (2022) | MIIT + MPS Notice No. 60/2022 | 2022 update only addressed "raw materials." PACs remain not included. |
1.3 Provincial Level: Sichuan as the Benchmark
Most of China's PAC production is concentrated in Sichuan Province. Effective July 1, 2025, the Sichuan Provincial PAC Safety Regulations (adopted by the Sichuan Provincial People's Congress on May 28, 2025, 22 articles) became China's first provincial legislation specifically governing PAC products:
- Scope (Art. 3): "射钉器材" includes both powder actuated tools (射钉器) and cartridges (射钉弹)
- Multi-agency oversight (Art. 5-10): Public Security, MIIT provincial branch, Emergency Management, Market Regulation, Cyberspace Administration, and Postal Administration each have defined responsibilities
- Flow registration (Art. 12): Manufacturers and sellers must register sales information through the public security information platform within 7 days
- Product traceability (Art. 13): Unique serial numbers must be cast on tools and printed on cartridge packaging — including manufacturer code, production date, and sequence number
- Prohibitions (Art. 15): Firearms modification is prohibited; unauthorized mailing or carrying of PAC products is prohibited
Exporters should verify whether the province of manufacture has similar provincial regulations. PAC products manufactured in Sichuan carry additional traceability requirements that may be relevant to export documentation.
2. Verified Customs Seizures (2023–2026)
| Date | Customs | Quantity | Declared As | Outcome |
|---|---|---|---|---|
| Jun 2026 | Ningbo Beilun | 171,500 pcs | Fasteners | Detained |
| Jun 2026 | Ningbo Beilun | 40,000 pcs | Flashlights | Detained |
| Jul 2025 | Ningbo Beilun | 800,000 pcs | — | Detained |
| 2024 | Shanghai Waigaoqiao | — | Fasteners | Penalty |
| 2024 | Zhangjiagang | — | Equipment | Penalty |
| Jun 2023 | T Customs | 6M pcs / ¥828K | — | ¥70K Fine |
| — | Ningbo Meishan | 2M rounds / ¥820K | — | ¥70K Fine |
One pattern: misdeclaration of dangerous goods as general cargo. Penalties: detention, fines, credit downgrades, potential criminal liability.
3. The Five-Step Export Process
3.1 Step 1: DG Classification Report
From a CMA/CNAS-accredited laboratory. Must confirm UN 0323, Class 1.4S, and SP 347 compliance. See our classification report guide.
3.2 Step 2: Competent Authority Approval
Under IMDG Code Section 2.1.3.2, Class 1 explosives require approval from the Competent Authority of the country of production. In China, the competent authority structure is:
| Authority | Role |
|---|---|
| Maritime Safety Administration (海事局) | Primary competent authority for international maritime DG transport. Approves the Dangerous Goods Safety Transport Declaration and issues vessel fitness permits. Exporters must submit to the MSA at the port of loading (e.g., Shanghai MSA for Shanghai port exports: www.sh.msa.gov.cn). |
| Ministry of Transport | National regulatory body for DG transport; issues ministerial regulations and industry standards |
| CIQ / General Administration of Customs | DG packaging performance testing and usage inspection (two-step DG packaging certification, see Step 3) |
3.3 Step 3: DG Packaging Certification
Two mandatory sub-steps: (1) Performance testing by CIQ on packaging samples; (2) Usage inspection by CIQ on the filled package. Both certificates together constitute the complete DG packaging certification.
3.4 Step 4: Export Declaration
Through DG-certified ports. Accurate declaration of UN 0323, Class 1.4S, with MSA-approved Dangerous Goods Safety Transport Declaration. For Class 1.4S operational details at Shanghai port, see our fire extinguisher export guide.
3.5 Step 5: Certified Packing & Loading
By certified DG container packers, complying with IMDG stowage and segregation.
4. Stowage & Segregation (IMDG 42-24)
UN 0323 / 1.4S: on-deck in closed units permitted; under-deck on cargo ships permitted. Strict segregation from Classes 1.1/1.2/1.3/1.5, 4.2, and 5.2.
5. Why Ginga Logistics?
Ginga Logistics — MOFCOM-registered Class A freight forwarder specializing in DG logistics. Full PAC export support: classification → MSA approval → packaging certification → port booking → certified packing.
Contact
📞 +86-21-36522730 ｜ 📱 Mr. Li: +86-13661402228 cus11@gingalogistics.com
Mr. Allen Yu: +86-18616727183 cus17@gingalogistics.com / +86-18616727183 (Mr. Yu)
📧 cus11@gingalogistics.com / cus17@gingalogistics.com
Disclaimer: Customs cases cited from public records. Regulatory citations link to official sources (gov.cn, samr.gov.cn, sc.12348.gov.cn, imo.org, unece.org). This is not legal advice.