Dear Minister Li:
I am writing to you to express the strong support of the US-China Business Council for China’s work to update its ground regulations for the transportation of dangerous goods to align with the European regulations (ADR) and the United Nations’ Limited Quantity / Excepted Quantity provisions. Specifically, we encourage China to adopt regulations as they appear in the 2015 ADR.
The Limited Quantity / Excepted Quantity provisions recognize the low risk of the transportation of consumer products, as compared to larger packages. The exemptions provide relief small individual containers, from specific packaging, package testing, segregation and documentation requirements for ground shipments, allowing for the unobstructed delivery of small quantities of consumer products to consumers. The types of products covered by these exceptions are ones that are familiar to Chinese consumers, given their active use of ecommerce: aerosols, mouthwash, perfume, cosmetics, and detergents in packaging for retail sale or home delivery.
China’s robust ecommerce market is a world leader, but its efficiency and affordability is dependent on a well-functioning delivery system to ensure that customers receive their purchases in a timely manner, at a reasonable price. In order for that delivery system to continue to meet those standards, China’s B2C parcel carriers should be held to safety standards that makes sense for the low risk of the products they transport. China’s adoption of transportation regulations as they appear in the 2015 ADR will ensure both consumers and carriers are treated fairly.