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China Reclassification of Shells

ECPyro

ECPyro

Member
Joined
Apr 2019
Messages
13
Hi all,

So there has been rumors circulating that China and the UN are reclassifying 8”, and maybe 6” shells as 1.1g and banning them from being shipped to the US. I am trying to get a hold of my importer friend that can hopefully shed some light on this issue. We use a decent amount of 6” and 8” so losing that would be horrible. Does anyone else know about this issue that would not mind sharing with us?
 
Haven't heard anything about the reclassifying 6" shell as 1.1G, but we did accept the information that shells larger than 6" couldn't be exported to anywhere.
 
Here is the latest I read: Per Dun Pai Fireworks - This change happened when China reorganized their government customs & inspections teams in order to enforce retaliatory tariffs on goods coming into China. The new agency is also responsible for export inspection and has chosen to take a "by the book" approach. No recent accident has triggered this change. We are reaching out to experts world wide to ask for assistance. Are large shells really significantly more dangerous for shipping?

I know that Dun Pai & Wizard are doing drop testing. I'm sure others are too.

Here is the post from Wizard yesterday-
After one and a half month, shell suppliers are still trying to find a way to pass the UN classification test safely for 6 inch shells cuz no one wants to touch the red line. If we just do the test as before, some effects will be failed in drop test. And China Customs made an report on the 8 inch shell delivery issue today, which started all the affairs and set up the standard, said all the wrong classification issues will be strictly punished in the future.
For now we are focused on the 6" shells, the first and most important step is to pass the drop test. Wizard will keep updating the news.
 
I think the point here is that for years, instead of the specified tests being performed, most fireworks have been classified by assumption. It's been on the order of "All 6" color shells are assumed to be packaged to as to pass the tests to be classified 1.3G." Now they're actually starting to do the tests and finding out that many items assumed to be OK don't actually pass.

Please note that the tests such as the drop tests, heat resistance tests, etc. are as packaged for shipping, not testing the fireworks directly. If you've been buying product, you know that many large shells arrive in boxes that aren't even strong enough to support the weight of the fireworks, much less stand up to the drop tests.

From my own observation, I can't really dispute that many fireworks, and large shells in particular, don't pass the tests as they have been shipped for the past decade or more. Some small fireworks, such as waterfall tubes, also fail the tests. The manufacturers will have to rethink and redesign the shipping cartons and packaging.
 
The drop testing is of packaged or unpackaged articles. It is part of the series UN series 4 tests to determine suitability for transportation. Here is a link to the UN document that defines these tests.


The series 4 tests are yes/no result tests to determine if an explosive (firework) is safe to transport without the danger of accidental ignition from dropping or heat.

The drop test does not determine classification (EG. 1.4G, 1.3G or 1.1G)

The classification of fireworks to 1.1G, 1.2G, 1.3G, 1.4G is done using the series 6 tests. Series 6 tests are done on packaged articles.

I have had UN series 6 testing done on a number of products that I import into Canada. These products were classified using the UN Default Fireworks Classification Table as 1.1G and upon testing 1.3G classification was the result. I can say from my experience that it is very possible for a 6" shell to test as 1.1G if it had a substantial flash powder burst charge. I am also almost completely certain that a 72/1 box of 3" salutes with 1 color shell in it as is commonly sold in the USA would be 1.1G or 1.2G as long the salute has good quality flash powder in it as most salutes do. Also if the manufacturer cheaped out and used chlorate instead of perchlorate in the salute it is pretty much a certainty that the chlorate salutes would be 1.1G due to the much higher sensitivity of Chlorate compositions. Chlorate is cheaper than perchlorate so the profit motive is there

It is possible to package 3" salutes as 1.3G. This is how salutes are imported into Canada. Unfortunately this requires separation and packing in the box such that 1.3G packaged salutes are 18/1 in a box that is a bit larger than a 72/1 3" shell box. Due to the higher shipping and packaging cost it makes a 3" salute quite a bit more expensive.

If you think about it paying the extra expense and having 1.3G salutes might be a better solution that having a big pile of 3" salutes packed 72/1 accidentally ignite and cause a major accident causing injury and death. You know that is likely to cause regulatory action that would not be good for the fireworks industry. I would say to those guys that have a big pile of 72/1 3" salutes a good safety measure would be to put them in smaller piles in the magazine with other 1.3G or 1.4G products in between them. The nature of a 1.1G explosion is everything goes in one event because the shock of the explosion initiates all of the 1.1G material at once. At least if the salutes were in smaller piles separated by non 1.1G material each 1.1G explosion would be smaller.
 
Had a look at the testing video on the Dun Pai facebook page and the test looks like a UN 6b test. They don't show much but it looked like boxes in a hole about 1 meter from the top of the boxes to ground level. The prescription for the UN6b test requires the fireworks to be ignited while contained under a meter of sand or dirt to contain it to simulate boxes packed in a shipping container or truck box. I am assuming that they filled in the hole before igniting the fireworks.
 
Saw the latest news on an facebook account: Scott McDonald. Quote some words from his facebook:"
11/26/19:After further evaluation of 6" and 8" shell, the governing agency has determined that 6" and 8" shells are now to be considered 1.1G EXPLOSIVE and CAN ONLY to be shipped by CLASS A company."
 
I posted the info below recently on a Canadian forum so I thought I would repost it here. I hope this helps keep the 6" shells coming into the USA without extra packaging and the extra shipping expense that come with it.

I just had several hundred cases of 6" shells go through the first step of clearing the new system for inspecting/testing 6" shells. The testing lab selected 4 shells. 2 were Vortex Thunder and Silver Tail to Reports. Both are shell of shells with salutes inside. The other 2 were color shells. All of these shells have substantially less flash powder than the 25% where the UN Default Classification Table rules them as 1.1G. The lab declared over 25% flash powder which is incorrect. We took it up with the manager of the lab by presenting the technical information and the UN6B tests and showing how the lab had calculated the flash powder content incorrectly. The Manager agreed and passed the shells for shipment.

These shells are packaged in the usual boxes 9/1 and 10/1 with no additional cardboard or other packing.

Now the containers will go to Customs where they may be tested again so I will post the result of that when it happens.

It seems that the Chinese are applying the 25% flash powder content rule from the UN Default Fireworks Classification Table. Canada has applied the 25% flash powder rule since 2005. There are some problems with the testing in China. Hopefully the end result will be we can still get 6" shells and the shells that really are 1.1G are classified properly. It would not be good for the industry if one day a container of 1.1G 6" shells blows up at someones storage at 1.3G distances and kills or injures someone. No one wants people to get hurt or killed and the regulatory response to such an incident would likely not be good for the industry.
 
As promised in my previous post here is what happened when the containers arrived at export customs in China. Much to our surprise there was no mention of the 1.1G/1.3G 6 inch shell issue. I can only assume that the lab results from the shipping company inspection were accepted. Instead the containers were refused for export because the fireworks were from a different province than the one they were being exported through. With the help of a factory from the province of export we were able to negotiate the export of the containers after about a week of delay. We had heard about a similar export policy in another province but not in the province we were exporting through. This is another example of the unstable situation of fireworks regulation in China.

In my opinion the regulatory difficulties in China are not specific to fireworks. The Chinese government will take action with no concern for industry or the supply chain if it wants to do something. They have been trying to reduce injuries and deaths in industry and stop corruption. They have been jailing or executing people for corruption when there has been an industrial accident caused because the officials were looking the other way due to corruption. I think this is resulting in officials scrambling to make sure everything under their watch is within regulations when they feel the attention is on them.

The result of the latest action on 6" and 8" shells is that the 25% flash powder rule from the Default Fireworks Classification Table is being applied in China. This result is good as shipping and storing 1.1G material as 1.3G could result in a terrible accident. The bad side is the way China introduces new regulatory measures is disruptive and expensive for industry.

The Dunpai Blog post referred to by Fuse
says "An “investigation team” of technocrats". Technocrats by their nature look at the technical aspects of a problem and try to solve it by the best technical solution. From what I see the technical solution they are looking at is the UN Fireworks Default Classification Table. The UN Fireworks Default Classification Table classifies fireworks by analogy to existing fireworks designs. Here link to the table.

The link to the table is to an Australian government website. There is nothing specifically Australian about the table. It was just the 1st website that I found that had the table by itself, not buried in a much larger document.

The table was developed by the United Nations Economic Commission for Europe unece.org.org
It is used by most European countries, Great Britain, Australia, Canada and most other developed countries but not by the USA.
Both China and the USA participated in the developing the Table but at the present time both countries do not use the table and it has no legal status in the USA or China.

There was lots of fireworks science done in many countries to develop the table including the CHAF project where they blew up whole containers of fireworks to see what classification they should be.

Here is a quick explanation of fireworks classifications
1.4s no significant effect outside the packaging
1.4G no significant projection of fire beyond 5 meters
1.3G major fire hazard minor explosion hazard
1.1G instantaneous Mass explosion

To arrive at these results there are specific tests UN series 6 tests that involve containment, witness screens, witness plates and ignition methods that are described in the prescriptions for UN6a, UN6b, and UN6C tests.
 
New 6" shell packaging. Our supplier landed 6" shells in the US in 2020, but got no 8" shells. They hope to get 8" shells next year, said it might take 1/1 packaging to get them approved. More disturbing, no salutes(only) in any size were allowed to be exported in 2020, at least to this one wholesaler. Picture is new packaging vs. old packaging.New Shell Packaging.jpeg
 
I managed to get 6" shells out of China in the old style packaging when other companies were forced to use the new style packaging. This requires the UN series 6 test results presented to the export control authorities in China. I have been importing salutes in packaging that changes them from 1.1G to 1.3g since 2008 which is what the new packaging is for. The game has Changed. China no longer allows fireworks to be manufactured to the standards and regulations of other countries. All classification is now done by the UN Default Fireworks Classification Table. If you want to have fireworks classified differently than the table you must do UN Series 6 testing. Also addressing the early comment about NOABS, they will be classified 1.3G under the default table as they are loaded in a tube and have more than 25 grams powder weight per shell (Shot Tube from the default table) My guess is it is just a matter of time until the Chinese get to it. The thing that really annoys me is that the default table is largely based on flash powder loaded European consumer fireworks and Canada and the USA do not allow the amount of flash powder allowed in European Consumer Fireworks. 130mg is the USA limit and 800 mg is the Canadian limit with lower amounts allowed in different firework types. I know I repeated some info from a previous post with the link to the default table. I did this to put the info all together. The link to the table is 3 posts above.
 
Ace Pyro must have solved the packaging and testing:

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Al Giordan

June 15 at 11:48 PM ·
Shared with Members of Pyro Universe

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