In January, 2025, the National Technical Committee for Standardization of Hazardous Chemicals Management officially issued the draft national standard titled Packaging for Dangerous Goods — Packaging, Intermediate Bulk Containers (IBCs) and Large Packagings — Guidelines for the Application of GB/T 19001 (Draft for Comments). This document revises the existing standard GB/T 27865-2011 of the same name.
The draft is currently available for public consultation for a 16-month period and is scheduled to take effect three months after its formal publication.
Background
In recent years, the safety management of dangerous goods has encountered increasing challenges both within China and internationally. The level of safety oversight for dangerous goods packaging across China remains uneven, with gaps in systematic quality management systems and limited alignment with international regulatory frameworks. These shortcomings have affected both trade development and overall safety management.
To enhance the quality of China’s dangerous goods packaging industry and improve harmonization with global standards, the National Technical Committee for Standardization of Hazardous Chemicals Management completed a revision of the guidelines for applying GB/T 19001 to dangerous goods packaging. The draft standard is intended to provide structured guidance for packaging manufacturers on implementing effective quality management systems, thereby supporting the safe, environmentally responsible, and sustainable development of the industry.
Scope
This document sets out guidance for applying quality management systems to the manufacture, measurement, and monitoring of approved design-type packaging for dangerous goods, including packagings, intermediate bulk containers (IBCs), and large packagings (LPs).
It applies to organizations that:
a) Need to demonstrate their capability to consistently supply products and services that meet customer requirements as well as applicable legal and regulatory obligations;
b) Seek to improve customer satisfaction through effective system implementation, including continual improvement processes and ensuring compliance with customer and regulatory requirements.
Key Technical Revisions Compared with GB/T 27865-2011
1. Updated Reference Standard
The technical basis has been updated from GB/T 19001-2008 to GB/T 19001-2016, aligning Chapters 4–10 with the corresponding clauses of the 2016 version.
2. Addition of Industry-Specific Requirements
New sector-specific provisions for quality management systems in dangerous goods transport packaging have been incorporated, including:
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Clause 7.5.1: Specifies that the quality management system must include documented information required by this document, as well as any additional documentation deemed necessary by the organization to ensure system effectiveness.
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Clause 8.4.1: Strengthens controls over external suppliers by requiring purchased materials or components to comply with approved design type specifications and to be verified through certification or testing.
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Clause 8.5.1: Enhances production control requirements. Visual inspections are mandatory following changes to process parameters. If design characteristics are altered, retesting must be conducted in accordance with the relevant provisions of the UN Model Regulations. The clause also requires validation of manufacturing process parameters, design type testing, and formal approval.
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Clause 8.7.1: Improves controls for nonconforming outputs by integrating corrective and preventive actions, such as batch inspections or increased testing frequency when nonconformities occur during production.
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Clause 9.1.1: Reinforces performance monitoring requirements by mandating the identification of equipment adjustment needs through visual or automated monitoring. Initial samples must be examined to confirm compliance with the technical requirements specified in Appendices A through C.
