According to Announcement No.81 of 2021 issued by the General Administration of Customs,effective October 15,2021,ammonium chloride for fertilizer use has been included in the“List of Import and Export Commodities Subject to Mandatory Inspection”and will undergo export commodity inspection.

The export commodity catalog for ammonium chloride includes two entries:ammonium chloride for fertilizer use(HS code:2827101000)and ammonium chloride for non-fertilizer use(HS code:2827109000).Previously,many ammonium chloride exporters directly exported under the non-fertilizer grade classification(Code:2827109000).A key criterion here is whether the exported ammonium chloride genuinely qualifies as non-fertilizer grade.

From a strict regulatory perspective:Exporting goods subject to statutory inspection without prior declaration or inspection is prohibited.This is because determining whether exported ammonium chloride is for fertilizer or non-fertilizer use cannot be self-defined by enterprises.Compliance requires professional testing by authorized institutions and issuance of corresponding certificates.Consequently,ammonium chloride exports now face significantly stricter controls than before,resulting in extended export timelines.

Below is an ammonium chloride export penalty case presented by Shandong Customs(for reference):

In 2024,Company A declared an export of 64 tons of food-grade ammonium chloride to customs under commodity code 2827109000,without specifying an export inspection and quarantine supervision category.Following inspection and classification per control instructions,customs determined the goods should be classified under commodity code 2827101000(ammonium chloride for fertilizers)with an export commodity inspection supervision category,making it subject to mandatory inspection.Company A exported the goods without declaring them for inspection to customs,violating Article 15 of the Import and Export Commodity Inspection Law of the People's Republic of China and Article 24(1)of the Implementing Regulations of the Import and Export Commodity Inspection Law of the People's Republic of China.

Company A's violation constitutes a general administrative penalty offense.and the customs authority,in accordance with Article 32 of the Law of the People's Republic of China on the Inspection of Imported and Exported Commodities,Article 43 of the Regulations of the People's Republic of China on the Implementation of the Law of the People's Republic of China on the Inspection of Imported and Exported Commodities,and pursuant to Article 11(1)of the Customs Administrative Penalty Discretionary Benchmarks(II)(Announcement No.187 of the General Administration of Customs in 2023)and Item 39 of Annex 2“Common Discretionary Benchmarks for Customs Inspection and Quarantine Administrative Penalties,”imposes a fine on Company A.Pursuant to Article 28,Paragraph 1 of the Administrative Penalty Law of the People's Republic of China,the Customs ordered Company A to rectify its illegal conduct.