Exporting Chrome Oxide Green: The Compliance and Documentation Checklist

Chrome oxide green moves across borders as an ordinary industrial pigment — not dangerous goods — but the paperwork still decides whether your container clears customs in days or waits weeks. Here is the full checklist.

1. Transport classification

Chromium oxide green is NOT classified as dangerous goods under IMDG, IATA or ADR — UN number: not applicable. Ship it as ordinary cargo, but attach the SDS to every consignment so forwarders and inspectors see the classification immediately.

2. The SDS itself

A 16-section SDS in REACH Annex II format (as amended by 2020/878), GHS-aligned, with the sections in the destination-country language where regulation requires it. Not classified per CLP — but the "not classified" statement must be explicit, not assumed.

3. Cr(VI) certificate per lot

The document customers actually ask for: hexavalent chromium content per production lot — ≤ 10 ppm standard, ≤ 5 ppm low-Cr(VI), ND for micronized. Include the test method (ISO 4621 or the supplier's validated method) and the lot number that links to the packaging.

4. REACH statement

Registration confirmation (the substance is registered), Annex XVII confirmation for Cr(VI) restrictions as applicable, and SVHC statement (the product contains no SVHC above threshold as supplied).

5. RoHS confirmation

2011/65/EU RoHS: chromium oxide pigment contains none of the restricted substances above limits — Cr(VI) in the supplied pigment is below the 1000 ppm threshold and, as an inorganic pigment used in components, is typically outside the directive's scope. State both clearly.

6. Country inventories

TSCA (US), DSL (Canada), AICS (Australia), CSCL/MITI (Japan), KECI (Korea), PICCS (Philippines), NZIOC (New Zealand), IECSC (China). A one-page inventory table with status per country solves most destination queries before they are asked.

7. Certificate of analysis per lot

Full test values — Cr₂O₃ content, D50, screenings, water-soluble salts, pH, oil absorption — with the standards cited (ISO 4621, ISO 787). This is the document your customer's QC department files against.

8. GHS label and packaging marks

Even unclassified, mark the package clearly: product name, CAS 1308-38-9, lot number, net weight, and the standard precautionary dust note ("avoid inhaling dust"). Correct 25 kg paper bags or big bags per Incoterms requirements.

9. Origin and commercial documents

Certificate of origin (Form E / COO as applicable), commercial invoice, packing list with lot mapping. Make the lot numbers traceable from the COA to the invoice line — that single link is what auditors remember.

The verdict

Chromium oxide export compliance is not complex — it is disciplined. Prepare the nine documents once, maintain them per lot, and your shipments clear faster, audit cleaner, and customers stay longer.

The export documentation stack

The compliance calendar: what must exist before the first pallet

Export compliance is a calendar, not a document. Each requirement has a validity period, a renewal cycle and a jurisdiction, and the exporter who treats them as one-time paperwork discovers the gaps at the border. The working calendar: CoA and SDS — every lot, generated at dispatch; REACH registration — continuous, with the tonnage band matching the actual export volume, and the only-representative appointment current; RoHS and Cr(VI) declarations — per consignment for electronics and consumer goods buyers, refreshed when the product spec changes; GHS classification review — at least annually, because national implementations of GHS diverge and a label valid in one market can be non-compliant in another; customs documentation (HS code, origin, valuation) — per shipment, with the HS classification reviewed whenever the product description changes. The exporter's desk should show, at any moment, which documents are current, which expire next, and which jurisdiction changed last. Compliance is maintenance, not achievement.

The HS code question, answered honestly

Chromium oxide green sits under HS 2819.90 (chromium oxides and hydroxides, other), but the honest answer to “what is the right code” is: the code that matches the product's composition and use in the destination's tariff book — and the destination's book is the one that matters. Misclassification is the most common compliance failure in the pigment trade, and it is rarely deliberate: a product described loosely on the invoice, a code copied from a different product line, a destination tariff updated without notice. The cost of error is not just duty — it is seizure risk, audit exposure and a compliance record that follows the exporter into every future shipment. The professional practice: classify with the composition in hand (Cr₂O₃ content, purity tier, physical form), verify against the destination tariff, document the classification rationale in writing, and re-verify when the product or the tariff changes. A one-page classification memo per product is the cheapest insurance in the export function.

REACH in practice: what “registered” really means

“REACH registered” is a phrase that deserves unpacking, because it hides the difference between a registration that covers your product and one that covers someone else's. A chromium oxide green consignment entering the EU is legal when the substance is registered for the correct tonnage band by the exporter, an importer, or an appointed only representative — and the registration must match the substance identity (Cr₂O₃, not “chromium compounds” generally) and the actual tonnage. The practical checks: the registration number appears on the SDS and matches the substance; the tonnage band covers the annual export volume; the only-representative agreement is current and names your company. Beyond registration, the downstream duties matter: SVHC candidate-listing updates, restriction entries under Annex XVII, and the authorisation clock for Cr(VI) where applicable. The buyer's question — “can you prove your REACH status” — is answered with the registration number, the SDS in REACH format, and the OR agreement, not with a brochure sentence.

Cr(VI) declarations: the line that opens or closes markets

For electronics, consumer goods and any regulated downstream market, the Cr(VI) declaration is the document that decides whether the consignment is a product or a problem. The declaration states the hexavalent chromium content of the material — typically ≤ 5 ppm for the Low-Cr(VI) tier — with the test method named (diphenylcarbazide per ISO 2080 is the market convention). The trap for exporters is declaring the product line average while shipping individual lots: the declaration must be true lot by lot, and the buyer's own incoming testing will check it. The second trap is declaration scope — a Cr(VI) statement about the Cr₂O₃ content that quietly ignores the packaging, the pallet treatment or the moisture level is incomplete. The professional practice is one declaration per lot, method-named, signed, and archived with the CoA — so the buyer's RoHS file and the exporter's defence are the same document.

Country-specific landmines worth knowing

• EU: REACH registration + CLP labelling in the destination language(s); SDS format per Annex II; SCIP database notifications for articles containing SVHC.
• USA: TSCA inventory status, SARA 313 reporting where applicable, Prop 65 warnings for Cr(VI)-relevant products in California.
• China (import): GB/T 16483 SDS format differs from GHS-REACH; import declarations require the Chinese-format SDS and registration under the new chemical substance framework where applicable.
• Japan: CSCL/ISHA notification, Japanese-language SDS, Poisonous and Deleterious Substances Act checks.
• South Korea: K-REACH registration by tonnage, Korean-language SDS with GHS Korea details.

The five-minute document audit

An exporter can grade its own compliance posture in five minutes with five questions: (1) Is there a current SDS in the destination's format and language for every product shipped? National GHS implementations diverge; a US-format SDS is non-compliant in the EU, Japan or Korea. (2) Does every lot ship with a matching CoA, and is the archive complete? The archive is the defence; gaps are discovered at audit, never in advance. (3) Is the REACH registration (or the OR appointment) current for the actual tonnage? Tonnage-band creep is the classic silent failure — exports grow, the registration does not. (4) Is the Cr(VI) declaration true lot by lot, method-named and signed? A declaration that is not lot-specific is a claim, not a certificate. (5) Is the HS classification documented with its rationale, and reviewed within the last year? An undocumented classification cannot be defended when challenged. Five yes answers and the exporter is ahead of most of the market; one no, and the next border crossing is a lottery ticket.

When things go wrong: the customs query

Every exporter eventually receives the email: the consignment is held, the documents are questioned, and someone wants evidence within a deadline. The organisations that answer calmly all share one habit: the archive is real. The CoA for that exact lot, the SDS current at dispatch, the declaration signed on the dispatch date, the classification memo — each retrievable in minutes because each was archived against the lot number at the time. The organisations that panic share the opposite habit: the paperwork was generated but not kept, or kept but not organised, and the reconstruction takes days while demurrage accrues. The archive is not a compliance flourish — it is the exporter's response time, and response time is what the customs authority actually experiences. Build the archive at dispatch, and the customs query is an email; build it during the query, and it is a crisis.