Pyro Shipping Crisis

Pyro Shipping Crisis – Recently some well meaning but incorrect information is being posted on Facebook. We will try to get the details correct and explain how this will impact your fireworks production & shipping worldwide. You can learn more at http://dominatorfireworks.com/Global_Fireworks_Crisis.html or the twitter hashtag #PyroShippingCrisis https://twitter.com/hashtag/PyroShippingCrisis…

Fact Check – RTS & “High Risk Fireworks”
In Spring 2020 the private group Shanghai Fwks Transport Assoc (SFTAT) decided to test all fireworks over 1.2 inches as “High Risk”. This is a private association of logistics companies, it is not the China government and it is not the fireworks factories or wholesalers.
RiGour(RTS) is a private testing company they hired to enforce the rule. If you don’t pay for the RTS testing sticker, then the private Shanghai Logistics Association will not agree to allow your shipment to pass through the Shanghai port. Currently, Shanghai is the only major Chinese port allowing fireworks. Therefore, if SFTAT decides not to allow shipping then effectively almost all fireworks shipping stops.
On Oct. 28th, 2020 SFTAT sent a letter to all fireworks exporters stating that due to the Shanghai Expo Nov. 5-10, shipping will be stopped until further notice. Shipping has not resumed yet.
The issue is how SFTAT & RTS are using the words “High Risk”. First off, they are using their own private authority, this is not any form of government rule or regulation. Second, focusing only on tube diameter they are incorrect in assessing risk correctly.

Conclusion: 1.) “High Risk” is a “made up term” and has no validity from any government regulation. 2.) Using tube diameter to assess risk is incorrect. 3.) USA fwks are NOT “High Risk”. 4.) RTS is a private company, not government group.

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Confusion over importance of Tube Diameter in Fireworks Hazard Rating 对管径在定义烟花爆竹危险级别中重要性的困惑

Topic: Confusion over importance of Tube Diameter in Fireworks Hazard Rating

主题:对管径在定义烟花爆竹危险级别中重要性的困惑

Drafter:  Matt Palaszynski (Dunpai Fireworks)

作者:马特(盾牌烟花)

The Liuyang Fireworks industry recognizes that leaders in Hunan Customs face a legal documentation problem where Beijing General Customs have made it very difficult for the Hunan Leaders to meet the needs of the Fireworks Industry and the legal requirements of General Customs of Beijing.

浏阳烟花爆竹产业的所有人认识到,湖南海关领导面临着一个法律文件问题,即湖南海关很难同时满足烟花爆竹产业的需求和北京海关总署的文件要求。

As leaders of the fireworks industry, we understand this difficult position of Hunan Customs.   Our goal is to help Hunan customs solve the “legal issue” in the General Customs documents and more importantly to reduce the true risk of fireworks shipping and transport.

我们理解湖南海关作为烟花行业的领导者的困境。我们的目的是帮助湖南海关解决海关总署文件中的“法律问题”,更重要的是降低烟花爆竹运输的真实风险。

The Problem问题: 出口烟花爆竹检验管理办法(2018修改)现行有效  (发文字号海关总署令第238号)[本文底部附有该文件]

– This document has been used since the year 2000.   In all of those years, the USA Standard for consumer fireworks (APA 87-1) has been considered to be a “higher standard” than the China Domestic laws and the UN Model Regulations.    Article 7 allows for the import country’s standard to be used in place of China regulations if the import country has a “higher standard”.     Recently there has been some confusion over the tube diameter.   Since USA law does not have a tube diameter limitation, and some USA consumer cakes use 3 inch or even 4 inch “fake tubes”, the mistake has been made people think that these larger tubes are more dangerous.   However, this is an error.   We will explain below in Appendix A & B that USA consumer cakes are in fact very safe (never a history of an explosion or injury in storage or transport – Appendix A) and we will explain what are the technical differences between the USA Regulations for consumer cakes and the UN Model Regulations and why the USA regulations are in fact “more strict”. – Appendix B.

本文件自2000年以来一直在使用。近几年来,美国消费烟花标准(APA 87-1)一直被认为是比中国国内法和联合国示范条例更严格的标准。海关总署令第238号第7条允许在进口国有“较高标准”的情况下,以进口国的标准取代中国的条例。近几年来,在管径问题上出现了一些困惑。由于美国法律没有限制管的直径,一些美国消费地礼使用3英寸甚至4英寸的“假管”,这个现象让让人们认为这些更大的管子更危险。然而,这是一个错误。我们将在下文附录A和B中解释美国消费地礼实际上是非常安全的(从来没有在储存或运输中爆炸或受伤的历史-附录A),我们将解释美国消费地礼烟花条例与联合国示范条例之间的技术差异,以及为什么美国的条例实际上“更严格”。-附录B。

Summary:  Tube Diameter is not the most important factor for determining risk.   Hunan Customs must evaluate burst charge and packing density as higher risk factors than Tube Diameter.

总结:管径不是决定风险的最重要因素。湖南海关须对开苞药和包装密度(产品间距,单位能量密度)进行评估,将其作为较高的风险因素,其次才是管径。

Problem Immediate Solution:问题立即解决方案

  • We note that the Problem is not an actual safety issue. In the past 20 years there has not been serious storage or transportation accident involving USA Consumer cakes.    Therefore, we feel this is more of a legal documentation issue as opposed to a true safety issue.    Evidence of this is presented in Appendix A.
  • Order #238, Article 7 states that the UN Model Regulations or the import Country’s Standard can be used if the import Country has a “Higher Standard”. Appendix B will provide evidence that the USA’s standard is in fact a “Higher Standard” (or equivalent) to the UN Model Regulations for Consumer Fireworks.

1.)我们注意到,问题并不是一个实际的安全问题。在过去的20年中,没有发生过涉及美国消费地礼的严重仓储或运输事故。因此,我们认为,这更多的是一个法律文件问题,而不是一个真正的安全问题。这方面的证据载于附录A。

2.)海关总署第238号命令第7条规定,如果进口国有“更高的标准“,则可以使用《联合国危险货物建议书规章范本》或“进口国标准”。附录B将提供证据证明,美国的标准实际上是《联合国危险货物建议书规章范本》的“更严格的标准“(或同等标准)。

Long term Solution:长远解决方案

  • Because this is Legal Documentation issue, we believe the long term way to resolve this issue is to modify Order #238 (as was done in 2018).
  • We suggest that Article 5 of Order #238 be amended to read. Manufacturers of export fireworks and firecrackers shall produce and store export fireworks and firecrackers in accordance with the relevant laws.   For export to the USA product should be built according to the Department of Transportation’s Hazardous Materials Regulations in Title 49, CFR and for USA consumer fireworks with the regulations of the U.S. Consumer Product Safety Commission (CPSC) published in Title 16, CFR.  For other import countries, follow the “United Nations Dangerous Goods Recommendation Model Regulations” and relevant laws and regulations.    *** Red is amended words.

 

  1. )由于这是法律文档问题,我们认为解决这个问题的长期方法是修改海关总署令第238号令(如2018年所做的那样海关总署令《海关总署关于修改部分规章的决定》修改)
  2. )我们建议将第238号令第5条修正为:出口烟花爆竹生产企业应当依照有关法律的规定,生产、储存出口烟花爆竹。出口到美国的产品应根据交通部第49卷中的危险材料条例和美国消费品安全委员会的条例制造,出口到美国的产品应符合美国消费者产品安全委员会的规定。(CPSC)发表于标题16,CFR。对于其他进口国,应遵循《联合国危险货物建议书示范条例》和有关法律和条例。***红色字体是修正词。


  •  

    Appendix A: 附录A:

    This section contains proof that USA Consumer Fireworks cakes are very safe and have never caused any explosion or injury in storage or transportation.

    Every year several Consumer Fireworks retail or warehouse storage locations are involved in an “ignition”.    The results have always been a limited fire with no explosion and no injury caused by the fireworks themselves.    Most of these fires are caused by arson where people set the fires out of mischief or curiosity.   In some instances it is suspected that the fires were set intentionally as an attempt to collect fire insurance money.

    We have done a very fast internet search and identified three examples.  There are many more examples for anyone willing to search:

    Example #1 – July 4th, 2019 5:45 a.m. Arson suspected in fireworks storage containers near Davey Jones Fireworks, FORT MILL, S.C.

    Fire only, no explosion.  No one hurt.  Cars can be seen driving very near the fire.

    https://www.wsoctv.com/news/local/massive-fire-breaks-out-at-fireworks-stand-in-fort-mill/963857892/

    本节内容证明,美国消费地礼烟花是非常安全的,从未在储存或运输过程中造成任何爆炸或伤害。

    每年都有几个消费者烟花零售或仓库存储地点涉及一个“起火”,结果一直是有限的火灾,没有爆炸,也没有烟花本身造成的伤害。这些火灾大多是由纵火引起的,人们放火是出于恶作剧或好奇。在某些情况下,有人怀疑这些火灾是蓄意纵火,企图收取火灾保险金。

    我们已经做了一个非常快的互联网搜索,并确定了三个例子。有更多的例子,任何人都愿意搜索:

    案例#1 -2019年7月4日5:45上午涉嫌纵火的烟花仓库附近的戴维琼斯烟花,福特磨坊,南卡罗来纳州。只有火,没有爆炸。没有人受伤。可以看到汽车在离火很近的地方行驶。

    https://www.wsoctv.com/news/local/massive-fire-breaks-out-at-fireworks-stand-in-fort-mill/963857892/

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    Example #2 – Sept. 24, 2018, Stateline Fireworks – Winchester, NH.  – Fire started by gunshot.   75 year old man arrested.    Fire only, no injury.

    案例2–2018年9月24日,州线烟花-温彻斯特,新罕布什尔州。–枪击引起了火灾。75岁男子被捕。只有火,没有伤害。

    https://www.unionleader.com/news/crime/suspect-in-fire-at-winchester-fireworks-store-is-headed-to-court/article_98d253bc-532f-5412-bad5-e2574050a55a.html

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    Example #3 – July 6, 2014 Gannett, TN.  Fire only, no explosion.  No injury.   Cars seen driving close to the fire.

    案例 #3-2014年7月6日,甘尼特,TN。只有火,没有爆炸。没有人受伤。看到汽车驶近火场。

    https://www.tennessean.com/story/news/local/2014/07/06/east-tennessee-fireworks-engulfed-in-flames/12272149/

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    Examples of deadly fireworks accidents:  (https://en.wikipedia.org/wiki/List_of_fireworks_accidents_and_incidents)

    Here are examples of deadly international fireworks accidents and an analysis of what type of product has caused the accident.    Note that ZERO deadly accidents were caused by USA Consumer Fireworks.   27 accidents were caused by Factory Explosions.   This also represents China’s greatest risk for accidents.   14 accidents were caused by 1.3g warehouses.  10 accidents happened in nightclubs which were caused by small non-explosive fireworks that caused a fire.  Finally 6 accidents happened in outdoor 1.3g displays.

    致命烟花爆竹事故的例子:(https://en.wikipedia.org/wiki/List_of_fireworks_accidents_and_incidents)

    下面是致命的国际烟花爆竹事故的例子,并分析了是什么类型的产品导致了这一事故。请注意,没有致命事故是由美国消费者烟花造成的。27起事故是由工厂爆炸引起的。这也是中国最大的事故风险。14起事故是由1.3G专业燃放烟花仓库造成的。夜总会发生10起非爆炸性小烟花引发火灾事故。最后在室外1.3G专业燃放表演上发生了6起事故。

    Table 1: Examples of deadly fireworks accidents:  表格1:致死烟花事故数据(https://en.wikipedia.org/wiki/List_of_fireworks_accidents_and_incidents)

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    The important point of this table is that USA Consumer Fireworks have never caused a deadly accident.   And therefore do not pose the risk that Hunan Customs imagines.   The large USA tubes are fake and used for marketing purposes only.

    本表的重点是,美国消费烟花从来没有造成致命的事故。因而不构成湖南海关想象的风险。大的美国筒子是假的套筒,仅用于营销目的。

    The real risk for accidents center on fireworks factories where loose powder & large quantity of semi-finished goods create a mass explosion explosive danger.   Many deadly accident both inside and outside of China confirm this fact.  Therefore the fireworks industry needs to focus on reducing factory manufacturing risk as the first priority.

    真正的事故风险集中在烟花爆竹工厂,在那里,散落的粉末和大量的半成品造成了大规模爆炸爆炸的危险。中国国内外发生的多起致命事故证实了这一事实。因此,烟花爆竹行业需要把减少工厂制造风险作为第一要务。

    The next risk for Hunan Customs revolves around the storage and warehousing of 1.3g fireworks.    Keep in mind that some United Nations 1.4g fireworks are classified as 1.3g in USA.   This is due to the use of powerful flash powder for the burst charge and due to lack of spacers between tubes.    So United Nations 1.4g cakes actually pose a much larger risk of causing deadly explosions than USA Consumer cakes.   This is a matter that should be taken very seriously by Hunan Customs.

    对于湖南海关,下一个风险是存储出口的1.3G专业燃放类烟花爆竹。请记住,一些联合国运输条例上定义的1.4G烟花在美国被列为1.3G。这是由于使用强大的金属粉末作为开苞药和由于缺乏筒子之间的间隔。因此,联合国运输条例上定义的1.4G地礼实际上造成了比美国消费地礼更大的风险,造成致命的爆炸. 这是湖南海关应该认真对待的问题。

    USA 1.3g cakes and UN 1.4g cakes cause “sympathetic propagation” due to the fact that each tube is touching one another with no “air gap” in-between.   This leads to one shot quickly igniting the shot next to it via shock and that leads to mass explosions.   These mass explosions are what cause deaths.    Deaths are not caused by cake insert shells acting as deadly projectiles.  Cake inserts do not contain enough kinetic energy to pose a serious threat of death in a transportation or storage accident.   Deaths are also not caused by fire unless there is a large crowd of people such as at a public display or indoor nightclub.   Public Displays and Nightclubs are not the not the responsibility of Hunan Customs.   Therefore, Hunan Customs should focus on “sympathetic propagation”

    美国1.3G地礼和联合国运输标准下的1.4G地礼引起“能量快速传导”,因为每个管子相互接触,中间没有“气隙”。这导致一发点燃后存在造成旁边的筒子也被同时点燃,从而导致大规模爆炸(瞬爆)的事故。这些大规模爆炸是导致死亡的原因。地礼的内筒作为致命的抛射物不会造成死亡。地礼的内筒不包含足够的动能在运输或储存事故中造成严重的死亡威胁。除非有一大群人,如在公共展览或室内夜总会,否则死亡也不是由内筒射出直接引起的。大型烟花燃放和夜总会烟花燃放不是湖南海关的责任。因此,湖南海关应注重“能量快速传导”

    Wire Cages have been used in the past, but they have been used to reduce a 1.3g item to a 1.4g item.   For example, Dutch Cakes that are clearly 1.3g (per USA standards) are shipped in wire cages to change them to 1.4g.     The purpose of the wire cage is not to stop the small 30mm shells from flying.   The wire cages are intended to prevent “sympathetic propagation” and reduce the chance of a mass explosion.   The Dutch are particularly aware of the risks of these powerful 1.4g UN Cakes because of the deadly Enschede fireworks disaster, where 23 people died.   So Europe uses wire cages to stop “sympathetic propagation”, the wire cages are not designed to stop the small 30mm shell from flying.

    铁笼在过去曾被使用过,但是现在已经被用来将1.3G的产品降低到1.4G。例如,荷兰地礼,显然是1.3G(根据美国标准)是要加铁笼运输的,以便把他们降低到1.4G。铁笼的目的不是阻止小的30毫米内筒飞行。铁笼的作用是防止“能量快速传导”,减少发生大规模爆炸的机会。荷兰人特别意识到这些1.4G联合国运输标准下的盆花的危险,是因为造成23人死亡的恩斯赫德烟火灾难。所以欧洲使用铁笼来阻止“能量快速传导”,铁笼的设计并不是为了阻止30毫米的内筒飞出来。

    Conclusion: Mass explosions are the main risk for Hunan Customs.   USA Consumer cakes do not mass explode.   We have 20 years of evidence and technical analysis to prove this point.   Wire Cages are used in Europe to prevent mass explosions.  They are not used to stop small shells from shooting.   If the goal was to stop small shells, then every cake, including 1 inch and smaller would need a wire cage.   When evaluating risk of fireworks small shells should “excluded” from the evaluation.   The UN Series 6c was written to classify Explosives and not fireworks.   Therefore, the evaluation criteria should exclude fireworks insert shells as these small paper projectiles do not pose any true deadly risk.

    Finally, fires started by fireworks at outdoor events or nightclubs are also a risk for fireworks in general, but Hunan Customs is not responsible.   Local fire officials can prevent these deaths by ensuring Fire Exits are available in buildings and restricting the use of indoor fireworks unless under supervisions of professionals.

    结论:大规模爆炸是湖南海关面临的主要风险。美国的消费地礼不会大规模爆炸。我们有20年的证据和技术分析来证明这一点。铁丝笼在欧洲被用来防止大规模爆炸。它们不是用来阻止小炮弹(内筒)迸射的。如果目标是阻止内筒(球),那么每个地礼,包括1英寸或更小的地礼,都需要一个金属笼。在评估烟花爆竹的风险时,应将内筒(球)排除在评估之外。联合国系列6c是用来分类爆炸物而不是烟花的。因此,评价标准应排除烟花爆竹的内筒(球),因为这些内筒(球)不构成任何真正的致命危险。

    最后,在户外活动或夜总会燃放烟花爆竹也是烟花爆竹的一个普遍风险,但湖南海关不对需此负责。当地消防官员可以通过确保建筑物有防火出口来防止这些死亡,并限制使用室内烟花爆竹,除非在专业人员的监督下。

     

     

    Appendix B: 附录B

    This section contains technical evidence fireworks are “more strict” then the UN Model Regulations or China Regulations.  

    USA Regulations Reference: Department of Transportation’s Hazardous Materials Regulations in Title 49, CFR and for USA consumer fireworks with the regulations of the U.S. Consumer Product Safety Commission (CPSC) published in Title 16, CFR.

    本部分包含技术证据,显示美国烟花爆竹比《联合国示范条例》或《中国条例》更“严格”。

    美国法规参考:运输部的危险材料条例的第49卷CFR,美国消费烟花与美国消费产品安全委员会的规定(CPSC)发表于标题16,CFR。

    https://www.americanpyro.com/assets/docs/PHMSADocs/apa stand 87-01.pdf

     

    Table 2: Technical Criteria for 1.4g Rating USA vs UN:  表格2:美国烟花标准和联合国标准对于1.4G烟花的技术参数对比

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    Conclusion, the UN Standard and USA Standard have different risk criteria.     Hunan Customs can’t only focus on Tube Diameter as the main risk factor.    A total of four risk factors must be evaluated.

    结论:联合国标准和美国标准有不同的风险标准。湖南海关不能把管径作为主要风险因素。总共有四个风险都必须进行评估。

    Table 3 will explain the reasons that USA cakes are less dangerous then cakes made per the UN Model Regulations.

    表3将解释美国地礼比根据《联合国运输示范条例》制作的盆花风险更低的原因。

    Table 3: Analysis of Risk for USA 1.4g cake vs UN 1.4g cake 3:关于美国标准1.4G地礼与联合国标准1.4G地礼的风险分析

    For Hunan Customs, the most common storage and transportation method for Consumer Fireworks will be in a 40 foot High Cube Metal Ocean Container.      These containers typically hold 68 CBM of fireworks.

    Therefore, in order to evaluate risk, Hunan Customs should look at the total Powder Weight and the total Flash Powder Weight in a full container of USA cakes vs UN Cakes.

    Using this evaluation it is clear to see that USA Cakes are in fact less dangerous and therefore the USA Regulations are “More Strict” then the “UN Model Regulations”.     Therefore, USA Cakes >30MM should be allowed to be classified as 1.4g as has been the tradition for more than 20 years.

    From this chart it is clear to see that the large USA 3 inch cakes are actually much safer for storage and transportation then the smaller, denser UN cakes.     In fact, the UN cakes contain about 200 times more of the powerful “flash powder” and about 10 times more total powder then the large 3 inch USA cakes.

    The reason the USA cakes have so much less powder is because they are mostly fake empty space used for marketing purposes to make them appear larger.   The goal is to “market the items” as more powerful, but in fact they are less powerful then the small, dense UN cakes.

    在湖南海关,最常见的消费烟花储存和运输方法是把烟花装在一个40英尺高的集装箱。这些集装箱一般装68立方米烟花。

    因此,为了评估风险,湖南海关应查看美国地礼与联合国规则下地礼全容器的总药量和总炸药重量。

    使用这种评估,可以清楚地看到,美国地礼实际上是不那么危险,因此,美国条例是比《联合国示范条例》“更严格”。因此,美国地礼30Mm应该被允许被归类为1.4G的传统已经超过20年。

    从这个图表中可以清楚地看到,美国3英寸(实际为2.25英寸的球或者内筒)的地礼对比较小,但是能量密度更大的联合国地礼,实际上美国地礼的存储和运输更加安全。事实上,一个40尺集装箱中,联合国规则下的地礼相比美线3寸9发地礼含有的白药高200倍,总药量比美线的3寸9发大10倍.

    美国药量少得多的原因是,它们为了市场营销,加入了很大的隔空让他们看起来更大。其目标是“推销这些物品”,使其看起来功能更强大,但实际上,它们的威力不如联合国的小一些地礼那么强大。

    Summary: UN cakes in a normal shipping container, contain 200 more dangerous flash powder and 10 times more total powder.

    摘要:联合国规则下的地礼在一个正常的集装箱中,含有200倍的白药和10倍以上总药量。

    7

    USA 3 inch 9 Shot cake vs UN 30mm 16 shot cake

    美线39发地礼对比联合国标准下的1.216发地礼

    The USA cake looks much larger and more dangerous, but in fact it contains much less total powder weight per CBM because it is mostly fake tubes, and empty space used to “market” the item.

    美线的地礼体积大很多并威力更大,但是事实上它包含的单位总药量更小,因为它大部分是假的筒管和用于市场营销的大体积.

    8

     

    Final Conclusion:最终结论

    Article 7 of import country laws to be used if they are “stricter” than the UN Model Regulations.

    出口烟花爆竹检验管理办法(2018修改)现行有效  (发文字号海关总署令第238号)

    第七条 出口烟花爆竹的检验应当严格执行国家法律法规规定的标准,对进口国以及贸易合同高于我国法律法规规定标准的,按其标准进行检验。

    We have proven both though 20 years of examples of No Accidents and through Technical Analysis that the USA law is in fact stricter for consumer cakes.

    The main reason that USA law is “stricter” is that it limits the very powerful “flash powder” which is about 10 times more powerful than normal Black Powder.      Also, the USA requires at least 13mm gap between each tube.   This space does two things.   1.) It limits the total number of “cakes” that can be loaded into a shipping container.    2.) The empty space acts to absorb the shock from one shot to another and prevents “sympathetic propagation” which is the technical factor that leads to deadly explosions.

    Conclusion:  Per Article 7 of Order 238, USA Regulations are “stricter” then the UN Model Regulations, therefore Hunan Customs should allow CIQ certificates to be issued for all USA cakes made per the USA Regulations (as has been done for the last 20 years without any storage or shipping accidents from USA consumer cakes in China or abroad).

    我们已经通过20多年的无事故案例和技术分析证明,美国法律实际上对消费地礼的定义规则更严格。

    美国法律“更严格”的主要原因是,它限制了非常强大的“白药”,威力大约是普通黑药的10倍。另外,美国要求每根管子之间至少有13毫米的间隙。这个空间做两件事。1.)它限制了可以装入船运集装箱的“地礼”的总数。2.)空旷的空间起到了吸收冲击的作用,防止了“交感传播”,这是导致致命爆炸(整体爆炸)的技术因素。

    结论:根据238号令第7条,美国法规比《联合国示范条例》“更严格”,因此湖南省海关应允许根据美国法规签发所有美国地礼的检验检疫证书(过去20年来,在中国和国外都没有发生过来自美国消费者蛋糕的储存或运输事故)。

     

     

     

    附件:

    出口烟花爆竹检验管理办法(2018修改)现行有效

    发布:2018-04-28实施:2018-05-01

    基本信息

    发文字号海关总署令第238号

    效力级别部门规章

    时效性现行有效

    发布日期2018-04-28

    实施日期2018-05-01

    发布机关中华人民共和国海关总署

    法律修订

    1999年12月2日国家出入境检验检疫局令第9号发布

    根据2018年4月28日海关总署令第238号《海关总署关于修改部分规章的决定》修改

    正文

    第一条

    为加强出口烟花爆竹的检验管理工作,保证出口烟花爆竹的质量,保障公共安全和人身安全,促进对外贸易的发展,根据《中华人民共和国进出口商品检验法》及其实施条例,制定本办法。

    第二条

    海关总署统一管理全国出口烟花爆竹检验和监督管理工作,主管海关负责所辖地区出口烟花爆竹的检验和监督管理工作。

    第三条

    出口烟花爆竹的检验和监督管理工作采取产地检验与口岸查验相结合的原则。

    第四条

    主管海关对出口烟花爆竹的生产企业实施登记管理制度。生产企业登记管理的条件与程序按《出口烟花爆竹生产企业登记细则》办理。

    第五条

    出口烟花爆竹的生产企业应当按照《联合国危险货物建议书规章范本》和有关法律、法规的规定生产、储存出口烟花爆竹

    第六条

    出口烟花爆竹的生产企业在申请出口烟花爆竹的检验时,应当向海关提交《出口烟花爆竹生产企业声明》。

    第七条

    出口烟花爆竹的检验应当严格执行国家法律法规规定的标准,对进口国以及贸易合同高于我国法律法规规定标准的,按其标准进行检验。

    第八条

    海关对首次出口或者原材料、配方发生变化的烟花爆竹应当实施烟火药剂安全稳定性能检测。对长期出口的烟花爆竹产品,每年应当进行不少于一次的烟火药剂安全性能检验。

    第九条

    盛装出口烟花爆竹的运输包装,应当标有联合国规定的危险货物包装标记和出口烟花爆竹生产企业的登记代码标记。海关应当对出口烟花爆竹运输包装进行使用鉴定,以及检查其外包装标识的名称、数量、规格、生产企业登记代码等与实际是否一致。经检查上述内容不一致的,不予放行。

    第十条

    凡经检验合格的出口烟花爆竹,由海关在其运输包装明显部位加贴验讫标志。

    第十一条

    各口岸与内地海关应当密切配合、共同把关,加强出口烟花爆竹检验管理和质量情况等信息交流。

    第十二条

    主管海关每年应当对所辖地区出口烟花爆竹质量情况进行分析并书面报告海关总署,海关总署对各关出口烟花爆竹的检验、管理工作和质量情况进行监督抽查。

    第十三条

    对违反本办法规定的,根据《中华人民共和国进出口商品检验法》及其实施条例的有关规定予以行政处罚。

    第十四条

    本办法所规定的文书由海关总署另行制定并且发布。

    第十五条

    本办法由海关总署负责解释。

    第十六条

    本办法自2000年1月1日起实施。

     

     

     

    Posted in 2020 | Tagged , , , , , , , | Comments Off on Confusion over importance of Tube Diameter in Fireworks Hazard Rating 对管径在定义烟花爆竹危险级别中重要性的困惑

    Complex situation unfolding in real-time,how fireworks regulations difference in US and China affects the products classification

    Here is an email from Matt to our customer:

    A meeting was held Saturday morning August 29th, 2020 by Liuyang/Hunan CIQ officers.   This is an on-the-fly update that represents the fog of a complex situation unfolding in real-time.  I do not know what will happen next.   I don’t know how serious this really is or if it will be squashed by higher authorities.    This situation has been building for months, and it escalated in the last week.    I kept hoping it would go away, but as of the conclusion of today’s meeting, it does not appear to be going away anytime soon, so that is why I am choosing to try to update you now.

    image001(08-31-09-17-01)

    1.)    The source of the problem is the USA Law for Consumer Fireworks is quite different than the fireworks laws in the rest of the world.     Most of the world, including China, follows a close form of the United Nations standard for fireworks.     For Consumer Fireworks, the UN standard says that cakes over 1.2 inch inside diameter are 1.3g unless tested in a UN Series 6 test and shown to be 1.4g.     USA law (APA87-1) says that tube diameter is not limited, but instead limits the total powder weight, the power of the burst, and requires ½ inch space for cakes over 200g.     This conflict between the USA and International laws has been in place for many decades.

     

    2.)    In the past, the China authorities have overlooked this conflict.    The assumption was that Chinese made fireworks would be allowed to be built and shipped according to the exporting country’s laws.  So USA products were built according to the USA law.   German products were built according to the German law.   Etc.      The issue with this “situation” is if an accident occurs with one of these “export” products on Chinese soil.    Liuyang is over 1,000 miles from the nearest port.   So USA fireworks must travel long distances on Chinese soil before they can reach international waters.    On December 4th, 2019 this type of accident happened.   A factory making large salutes (that technically were legal in the Eastern European country they were being shipped to) had an explosion.     When the federal authorities investigated the accident they used the China laws, not the laws of the Eastern European country, to determine what was legal and illegal.   The federal authorities determined the factory and the local officials were breaking China law.   Several people went to prison.   Many workers died.    Because of this Dec. 4th accident, the local officials in China have become spooked.  Last month they only planned to make 3 inch cakes 1.3g.   But after the Beirut Explosion they expanded it to include all cakes greater than 1.2 inch per the standard.    Asking them to compromise and not include 2 inch is not likely at this point.   They want to just stick to the regulation, which says all cakes greater than 1.2 inch are 1.3g by default.

     

    3.)    Specifically the recent trouble is coming from the Hunan Customs/CIQ staff.   I think the main reason this group specifically has been spooked is because they are new.    They recently formed in 2018 as a result of the USA/China trade War.     The USA put tariffs on billions of dollars of Chinese goods.    China retaliated and put tariffs on USA goods shipped to China.   However, prior to the Trade War, China did not have a well-organized Customs organization to control things such as inspecting USA imports and calculating tariffs.    Once this new, more powerful government agency was created and given power, they then started to expand their focus past just collecting tariffs on USA Soybeans.    One area they chose to focus on was fireworks.    For being such a small industry, fireworks always seems to draw an oversized interest from regulators both in USA, and now in China.

     

    4.)    The Hunan CIQ/Customs leadership holds a similar role to USA DOT, in that they issue the “classification document” to determine if a product is 1.4g or 1.3g.    So similar to a USA EX number.   The difference is that CIQ issues their “certification” for each batch of product produced as compared to the USA EX number which is only issued once.   Some big USA importers have considered this a limited problem because right now only Hunan CIQ is pushing this.   However, Hunan is producing 60-70% of the USA fireworks and if we consider the higher quality 2-3 inch cakes, it is closer to 80-90%.   So the idea that we can solve this problem by moving production to Beihai is not  a workable solution in my opinion.

     

    5.)    Customs/CIQ is not responsible for business.   Therefore, they don’t lose anything if business is harmed.    In fact, I believe they see it as their duty to try to stop businesses engaged in dangerous activity.  So similar to USA where EPA, OSHA, and other government agencies drove entire industries out of the USA due to regulations that were impossible to meet, this new China agency does not seem to care if China businesses are harmed.   In fact, I think they welcome it as a sign they are “being tough on safety”.    They have very little to lose from being “tough”.

     

    6.)    Unfortunately the top leadership in China, also does not seem to be a supporter of the fireworks industry.   They favor environmentally clean, hi-tech industry and consider fireworks a reminder of the “backwards, ancient” times.   In fact, over the recent years the China Domestic market has seen a slow-down mainly due to new Federal suggestions that “Fireworks are dirty, dangerous, and backwards”.   The federal government has gone so far as to try to use Fireworks and BBQ as a scapegoat for China’s massive air pollution problems.    The long winded point is that I believe there are strong political pressures from above working against the fireworks industry in China.   The industry as a whole is tiny compared to the China economy.

     

    7.)    Liuyang City stands to lose the most.   The mayor of Liuyang has come out against these Customs/CIQ changes.    But the provincial level Customs/CIQ is higher authority then the local mayor of Liuyang.    So I believe that we would need to get the Federal Level Customs/CIQ leaders to intervene if we wanted to stop this from occurring.   However, at this time, I am not aware of any individual company willing to attempt to talk to the federal authorities.

     

    8.)    In talking with major USA importers, the feeling as of today seems to be that this is a China problem and not a USA problem.     I don’t agree because the BASE of the problem is the fact that ONLY the USA deviates from the international UN standard.      Therefore, I believe that the easiest solution is for USA DOT to engage their federal level counterparts in China and work out a more legal solution to the problem created several decades ago when USA deviated from the UN Standard.     I think the USA government has a responsibility to help address this deviation and not expect private companies to work out a solution alone.

     

    9.)    To help put things into perspective, we estimate that USA is only about 13% of the total China fireworks industry.   This number would actually be even smaller if it were not for the recent reduction in the China domestic market.    So keeping in mind that USA is only 13% of the market, it becomes easier to understand why it is NOT likely that China factories and suppliers are going to be fighting on behalf of the USA importers.

     

    Possible Solutions:

     

    1.)    The best solution is for USA DOT and China Federal Authorities to talk and hammer out a document that allows USA goods to be manufactured, stored and shipped from the China Factory to China port, using USA law.    This has been the “unofficial” approach for the last 30 years.   So USA DOT and China Federal Authorities would just need to formalize what they have informally been doing for all these years.    Maybe it would require some small compromises on both sides.   Keep in mind this is all just paperwork.   It is a simple as a 1.3g vs 1.4g mark on the carton.     We suggested using both a 1.3g and 1.4g sticker on the cartons.    The 1.3g sticker would note “for China shipping only”.     This suggestion was rejected by Hunan CIQ, but perhaps if USA DOT raised this suggestion it would be accepted (this same issue applies to UN0431 vs UN0336).

     

    2.)    Hunan CIQ has already said that they will accept Series 6 tests as an alternative (see image below & https://www.unece.org/fileadmin/DAM/trans/danger/publi/unrec/rev21/ST-SG-AC10-1r21e_Vol1_WEB.pdf).

    So that means companies would need to pay to have each item tested and “graded as 1.4g or 1.3g”.    The question is who is allowed to conduct these tests.    Typically USA and China have been refusing to allow each other’s labs.   So China does not allow a USA lab result and USA does not allow a China lab result.    So the matter of what labs would be allowed to conduct these tests needs to be cleared up.   AFSL does not do Series 6 tests.   It needs to be an Explosives lab.  The 2nd issue is how to administer the Series 6 test.   Right now Hunan Customs/CIQ is insisting that any firework debris that flies over 50 feet (including a star) is 1.3g.  (a fiery projection emanating from the product is thrown more than 15 m from the edge of the packages or unpackaged articles.)  Hence their suggestion to use the Iron Cage.   But many USA & international testing labs interpret the “fiery projection” requirement differently and don’t count stars as projections in the Series 6 test (recent approvals of bulk 60g shells as 1.4g are examples of this different interpretation).   Logically, most 1.4g cakes, even 200g cakes, have stars that fly further than 50 feet.  So this means most cakes would be reclassified as 1.3g if tested.  They consider a fiery projection to be a continuous jet of flame or fiery gas.   So this aspect of the Series 6 test is a “debatable point” and different labs interpret “stars” differently.    Currently the test is very expensive in USA (thousands of dollars).   And applies product by product.   So some other mass testing method would need to be devised.   Maybe testing all 2 inch 500g cakes and getting a classification for all of them at once, instead of one by one.

     

    In conclusion, the testing solution, using a Chinese Test Lab.   Seems like a workable solution.   The challenge will be to come up with a lower cost solution (other than an Iron Cage) that stops projections.  Or changing the “interpretation” of what a projection is to not include stars as projections (as is the current interpretation by most international labs).   I also believe involvement from organizations like APA, NFA and US DOT to explain why the USA law should be accepted, could also be very helpful.

     

    We are very interested to hear your ideas and suggestions.     Soon we will need to make decisions to begin to build the items for 2021 or not.   We have already begun to print labels for some items.   So we will need to make decisions soon.

     

    Matt

     

     

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    The Dunpai fireworks team have a great summer breaks

    This year is truly a difficult year, while the world suffers in fear of  COVID – 19, on the other hand, the sales of fireworks reach history, It proves people like to shoot some fireworks during a hard time also pray for a peace and health world.

    COVID – 19 in China has made great progress due to the government’s strong measures to prevent the epidemic from spread which allow the team to travel over the province. this high heat shutdown , we hiked to Wugong mountain in JiangXi province , its altitude is 1918 merters, the weather is so great so can see the whole scenery from the top, we spent 4 hours climb the to peak. tired but happy!

    Sharing to you the unforgettable moment :

    微信图片_20200803101639 微信图片_20200803101657 微信图片_20200803101704 微信图片_20200803101713 微信图片_20200803101719 微信图片_20200803101739 微信图片_20200803101903 微信图片_20200803101908

     

     

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    Dunpai fireworks in action to overcome difficulties

    In today’s complex and severe international situation, Dunpai fireworks are still strong in adversity and make every effort to ensure a stable supply of goods to customers. Since the resumption of work, we have been working overtime every day to produce and deliver goods.

    6

    shipping

    Our product manager sacrificed his weekends to make sure the factory delivered on time by staying at the factory every day to inspect production. Our quality control manager will sample check dozens of goods every day, and test discharge after work time, every day to 8 o ‘clock. Our shipping department is off duty at 10 o ‘clock every day this month, so that each batch of goods can be delivered as early as possible.

    3 4 5 7

    8 9

     

    10 2

    Now that the virus outbreak is so severe in the United States, Dunpai fireworks are handing out free masks to every customer. Although the number is not large, it reflects the social responsibility of Dunpai fireworks. We sincerely hope that the outbreak can be over as soon as possible and the production order can be restored to normal as well.

    madical mask

     

    Please feel free to contact us if there are any we can do to help overcome the epidemic.sales@dpfireworks.com

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    Official report About Liuyang Fireworks “12 ·4” Major Accident Exposed contradictions, reflections and suggestions

    Changsha Emergency Management Bureau  Hu Chunshan

     

    Liuyang Fireworks “12·4” Major Accident had severe consequences,heavy losses,and profound lessons, which sounded alarm bells for all levels of supervision and the fireworks industry. The occurrence of this accident exposed many chaos in the production and operation of fireworks in our city, especially overcapacity, disordered markets, lack of management, weak supervision, lax enforcement of laws, the proliferation of molded products and the contradiction of safety and environmental protection. Need more attention. After the accident, the government attached great importance to making a series of instructions for accelerating industrial upgrading and transformation, improving the intrinsic safety of the industry, and promoting high-quality development,providing scientific guidance for the in-depth rectification, transformation and upgrading of the millennium traditional fireworks industry. In response to these problems, the Bureau went deep into the fireworks industry enterprises in the city, conducted extensive investigations, listened to the opinions of all parties, and formed a preliminary investigation report.

    1. Historical origin and basic situation

    1). Long history. The landform of Liuyang is mainly mountainous, hilly land (78%), which provides a natural protective barrier for the production of traditional fireworks with a high risk factor. Liuyang has a population of more than 1.5 million and has less arable land (12%). A large number of surplus rural laborers have met the development needs of this labor-intensive handicraft industry. Liuyang belongs to a humid climate with a mid-subtropical monsoon, with an average annual temperature of 17-19 degrees. It is extremely cold in winter, hot in summer, sufficient light, and moderate rainfall, which is in line with the climate required for the production of fireworks “no tide, no dryness, no freezing and no heat”. condition. In addition, the Chinese fir, bamboo, sulfur, red clay, saltpeter and other resources are abundant, providing good natural resource conditions for the production of fireworks. During the Ming and Qing Dynasties, Liuyang East, South, and West were engaged in the firework industry with more than 200,000 people, with an annual output of more than 140,000 boxes (200,000 per box). In the  the Qing Dynasty (in 1723), Liuyang firecrackers were listed as court tribute and entered the market in large quantities.In 1739, firecracker production entered commercial production, and Liuyang became the “center of Hunan firecracker manufacturing”. During the Tongzhi years, 80% of the households in Dayao, Jing gang, ChengtanJiang, Wenjia City, Yanghua were engaged in the production of fireworks. Box around. In the early years of the Republic of China, Liuyang firecrackers became a famous product in Hunan because of its “excellent manufacturing and reputation”. After more than 1300 years of development, Liuyang has formed an industrial cluster integrating production, operation, research and development, and logistics, and has become a world-famous fireworks production base and the world’s “hometown of fireworks”.

    2). Outstanding brand. As a traditional Chinese handmade product, Liuyang firework production uses traditional manual techniques, using soil paper, soil nitrate, sulfur, charcoal, red and white clay as processing raw materials, with 72 processes. After the founding of the People’s Republic of China, the government attached great importance to the traditional industry of fireworks, and set up research and management institutions such as the Fireworks Research Institute and the Fireworks Administration Bureau. The ancient traditional craftsmanship has developed from a simple and primitive handicraft workshop to a huge industrial cluster. In October 2002, Liuyang became the permanent seat of the International Fireworks Association Headquarters. In 2007, “Liuyang Fireworks” was officially recognized as a well-known trademark in China, ushering in a period of explosive growth. From 2010 to 2018, the total output value of Liuyang fireworks increased from 12.8 billion RMB to 25.92 billion RMB, with an average annual increase of 12.2%. The products are exported to more than 180 countries and regions on five continents, accounting for 50% of the domestic market and 70% of the international market. . In 2018, after advancing a round of rectification and exit, Changsha City still has 5,79 fireworks and firecracker production enterprises (549 in Liuyang and 30 in Ningxiang), accounting for 25% and 60% of the national and provincial production enterprises, respectively. At the same time, there are more than 600 supporting enterprises of raw and auxiliary materials for fireworks, with related industry income of 16.42 billion RMB. Throughout the industry chain, production and related industries provide about 350,000 jobs, and more than 10 billion RMB of workers’ wages are paid, contributing more than 4% to economic development of Changsha.

    3). Complete variety. There are many types of fireworks in Liuyang. There are thirteen major categories according to the effects of fireworks: cake, fountains, spinners, helicopters, rockets, roman candles, atrial shell, smoke, toys, combination items, hand-hold sparkling devices, etc. In recent years, through continuous innovation, we have successfully developed and launched high-tech new products such as micro (no) smoke fireworks, day view fireworks, indoor and stage fireworks, which are safe, reliable and non-polluting. Dancing Fireworks recently developed a low-sulfur, debris-free, safe and environmentally-friendly firecracker, which can even be displayed indoors. Continuous technological innovation and variety innovation capabilities are among the highest in the world. The firework firing has also been changed from traditional manual ignition to remote ignition, and the firing program is fully computerized.

    2.the main problems in the fireworks industry in Liuyang

    (1) Excessive production capacity. First, the capacity of major production areas has generally increased. After the country determined in 2004 that the fireworks would be concentrated in the Hunan and Jiangxi, other provinces (except Guangxi, Guizhou, and Yunnan) withdrew from the production of fireworks. The total output value of the fireworks production increased from 12.8 billion yuan in 2010 to 25.92 billion yuan in 2018, and the production capacity doubled in less than 8 years. Comprehensive production capacity in other major production areas inside and outside the province such as Shangli, Wanzai, Hepu and Liling has also generally increased over the same period.Domestic market demand continues to shrink, fireworks have a nationwide overcapacity;Second, the level of mechanization has increased significantly. In recent years, with the development of the mechanization of the fireworks industry, the production efficiency of fireworks has increased by more than 5 times, resulting in excess capacity in the process;Third, the production capacity of fully automatic production lines has expanded dramatically. In recent years, with the promotion and use of the fully automated production line of combined fireworks, the production efficiency of a single category of combined fireworks and fireworks has increased geometrically, resulting in the overcapacity of combined fireworks being more prominent than the overall market demand of other varieties.

    (2) The domestic market has shrunk sharply. In recent years, in addition to Beijing, Shanghai and other big cities banning fireworks, more and more cities have begun to ban firecrackers. In 2017, fireworks were banned in Tianjin. After that, many cities such as Changsha, Hefei, Jinan, Harbin and other cities issued “banning orders” in the form of legislation or government orders. There are currently 138 cities banned and 536 cities restricted in the country. With the continuous advancement of the blue sky defense war, the number of cities in China restricted from release is increasing, and the domestic market for fireworks and firecrackers has shrunk sharply. In 2018, fireworks and firecrackers sales in Beijing fell by 30.5% compared with last year, and the city’s total sales were 23000 cases, less than 4% of 600000 cases in 2009, a drop of 96.2%. This is the sixth consecutive year of decline since 2012. Other provinces are similar to Beijing. In 2018, Zhejiang province has fallen by 30%, Fujian province has fallen by 40%, Hebei province has fallen by 20%, Anhui province has fallen by 30%, Tianjin has fallen by 100%, and Shandong province, Sichuan province and Liaoning province have basically remained the same.

    (3) Inadequate development of overseas markets. Unlike domestic fireworks restrictions, the United States, Germany, Russia, the United Kingdom, Japan, France and other countries, the demand of fireworks has been increasing. According to statistics, China’s major exporters of fireworks and firecrackers are 42% in the United States, 21% in Germany, 7% in Russia, 6% in the United Kingdom, and 5% in Japan. In 2018, as a large number of fireworks and firecrackers produced in China (mainly Liuyang) are now safe enough, in the United States, except Massachusetts, the remaining 49 states can legally sell professional fireworks and consumer fireworks. In 2018, the United States alone consumed more than 900 million US dollars of various firework products, and about 70% of the fireworks used in professional firework shows were made in China.

    (4) The pattern of factories being scattered, small, and numerous has not been completely changed. First, there are many factories and production sites. As the main production area, the production of fireworks and firecrackers in Liuyang has undergone a workshop-to-factory transformation, and the number of factories has continued to decrease in the past 10 years. From 2016 to 2017, through policy phase-out, 362 factories and 82 industrial areas withdrew from the production field, and the number of factories decreased from 941 to 588. However, due to the large number of product types and specifications produced by the entire industry, it has objectively contributed to the existence of a large number of production units with small volume, large number, wide distribution, and effective demand. Therefore, during the ongoing “reorganization and upgrading” process, due to market demand, many small and medium-sized and micro factories would rather become the work areas of qualified factories (including branches and production lines), rather than withdraw from production. At present, there are still 800 production units including 549 factories and 251 production zones in Liuyang;Second, factory profits are low. In recent years, new investment in the whole industry has generally been relatively large. According to the “three-year rectification and replacement certificate” regulations, many factories and work zones must invest a lot of money in the rectification and upgrading of hardware for each rotation of safety production license. Almost all the money earned in the three-year production and operation cycle has been invested in rectification and reform. After several rounds of rectification and renewal, most factories are still operating at a loss. At the same time, due to the large number of factories, most products are homogeneous, some products are seriously overstocked. The product structure is contradictory, the competition is fierce, and the industry profits are thin;Third, production and operation activities are unstable. The seasonality of factory production is very strong, and is greatly affected by local policies, high temperatures, environmental protection and other factors. The frequency of temporary production suspension and temporary holidays is high, and the normal production and operation order is easily interrupted by humans. Workers are more mobile, working in free time and farming in busy time.

    (5) The overall safety operation capability is low. Except for a few factories in Liuyang, most of the factories and their managers lack of management ability, which is manifested in the following: the main responsible person has a poor sense of responsibility for the safety subject. Managers engaged in fireworks and firecrackers are generally older (average age is about 50 years old), most of them are farmers, handicraft producers and small commodity operators, and have not received systematic education, learning and management training, culture Low quality, lack of safety awareness and safety knowledge.

    (6) There is a huge risk of export concealment. Many export trading companies not only illegally place orders and ship illegally, but also smuggle fireworks products that are seriously overdose, out of scope, and extremely dangerous under the guise of export trade. The customs declaration deliberately conceals and disguise them as other general goods for export. It poses a great threat to transportation, and once an accident occurs, it will seriously damage or even destroy the entire industry. In recent years, the products of some export companies in Liuyang have been investigated in Shanghai and Ningbo ports, exposing the blind area of industry supervision.

    (7) The quality of the raw materials is not high, which makes the accident prone. The firework and firecracker industry is a high-risk industry. Unlike the machinery manufacturing and food processing industries, the quality and sensitivity of raw materials are directly related to the safety of all aspects of production, distribution and sales. First, there are many raw material manufacturers, and the phenomenon of “small, scattered, and chaotic” has not been eliminated. There are more than 600 raw material production factories, producing more than 1,000 raw material varieties, scattered in 16 towns in Liuyang; the second is the lack of raw material industry standards and uneven quality. Fireworks and firecracker chemical raw materials do not have industry-specific standards, and most raw materials are produced without standards, resulting in a flood of fake and shoddy products. For example, magnesium and aluminum powder, the price of aluminum and magnesium powder produced by the national standard aluminum ingot is 24,000 yuan per ton, and the price of aluminum and magnesium powder produced by recycling waste metal such as cans is only 14,000, but the cheap magnesium and aluminum powder has complex components and impurities. High content can easily cause accidents in the production process and product quality. In order to save costs, some companies have arbitrarily purchased low-quality raw materials for fireworks production. In addition, the lack of product testing equipment and testing technical personnel of fireworks enterprises, a large number of low-quality raw materials are used in the production of fireworks products, posing a major safety hazard of product quality.

    (8) Product quality specifications are not uniform and run counter to safety and environmental protection. First, non-degradable molded products brew systemic risks in the industry. In April 2012, the “new environmental protection moulded firework outer tube” was successfully developed in Liuyang, and then major companies followed suit. Molded firework products are formed by mechanically molding mineral materials at one time, reducing the 9 steps of the traditional process into 1 step, which greatly improves the production efficiency and promotes the development of mechanized production lines. However, the outer tube of this product uses waste paper, calcium sulfate, calcium carbonate, and stearic acid as raw materials. After the fireworks are fired, the solid waste does not have the recycling value of traditional paper outer tubes, which brings great pressure to the environment and sanitation. . This kind of product is difficult to degrade naturally (especially in the cold and water-absent North, the possibility of natural degradation is extremely small), runs counter to the national requirement of “garbage classification and reduction” . It has become a prohibited product in many provinces and cities (including traditional fireworks). However, many companies are spurred by fast production, low costs, and “earn fast money”. More and more followers have formed, leading to“bad currency to drive out good currency”, bring to great risk to the whole industry.

    3.Some suggestions for rectification and change

    (1) Smaller factories and work areas will be further eliminated, and factories that fail to meet the conditions for safe production will be retired by means of fund compensation, encouragement of transformation, and forced closure. Small and medium-sized factories with safe space for rectification and renovation, continuous market demand for products, environmental protection with development potential through technology upgrade, full guarantee of product quality and management capabilities, encourage high-quality factories to acquire, merge and reorganize and reduce the number of factories.

    (2) Comprehensively rectify the “work area (branch companies) affiliation” problem of multiple permits to eliminate regulatory blind area; Eliminate subcontracting, comprehensively clean up and inspect all fireworks and firecracker manufacturers, and subcontract and illegal  behaviors such as renting workshops, leasing stations, and multi-shareholder branch production are strictly punished and rectified within a time limit. If no rectification is made within the time limit or re-offend after rectification, the license shall be revoked according to law. Suspected crimes shall be transferred to judicial organs.

    (3) Improve the quality of raw materials. Establish a comprehensive law enforcement team, starting from the production, operation, and use of raw materials, strictly conducting random inspections, comprehensively checking and cleaning up high-risk materials with significant production safety risks, and severely investigating counterfeit and shoddy materials. Establish a “blacklist” system of raw materials, and promptly publish information on the investigation and punishment of inferior materials.

    (4) Stop production measures should be implemented scientifically in accordance with the law. First, follow the basic laws of fireworks and firecrackers production activities, scientific norms and temporary suspension of production, because of the particularity of fireworks and firecrackers production technology, the national technical regulations stipulate that pyrotechnics should be used immediately and cannot be retained overnight. After the normal production process of the factories is interrupted by temporary shutdown, all kinds of powder and semi-finished products may cause fire and explosion due to electrostatic accumulation, external physics, chemical reactions and other factors, resulting in great safety risks. If it is really necessary to stop production in a special period of time and other factors, there should be a reasonable buffer period; The second is to prudently implement high-temperature shutdown, which should be scientifically classified according to different product processes in summer. Technological products such as toy fireworks, micro-powder fireworks ,indoor fireworks and other products can be produced in different periods in summer, so as to avoid new hidden dangers caused by rushing orders after high temperature resumption, and achieve balanced production throughout the year. Third, the suspension of production during the Spring Festival and other holidays should follow the voluntary principle of factories, and factories should produce according to the needs of orders (especially the time limit for export products), which is conducive to improving safety.

    Posted in 2020 | Comments Off on Official report About Liuyang Fireworks “12 ·4” Major Accident Exposed contradictions, reflections and suggestions

    Summary of Dunpai Germany toy fair

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    From January 27, 2020, to February 2, 2020, our company participated in the toy fair held in Nuremberg, Germany. This big event is the 71st session. The exhibition area is divided into 12 sections according to product categories which are very large. It is indeed the largest toy fair in Europe. People crowded till the last day.exhibitors  has invested a lot of energy and money decorating their stands, it can be seen that they attach great importance to the exhibition.

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    This year is a key year for us to focus on the European market. We did have a lot of accumulation in the European market before but still, it is not enough, with globe economy facing great uncertainty in recent years, the European market gives us a better option to extend our business. so every new customer is critical for us in Europe.

    Although fireworks are only a small part of this toy fair, we do have many opportunities here. The toy fair  is a good platform to contact old and explore new, We have business talks with our old European customers. also, by all means, we gained some trusted new business. after the fair, we visited some of our customers in Germany and Belgium.

    Generally speaking, the development of the European market is still difficult. Customers here are generally very professional, demanding on product quality and relatively sensitive to price. After years of development, large companies like Weco Nico, often have established relatively mature supply chains. Relatively speaking, There are some small and medium-sized customers offer more opportunities for us , it would be better to start with them at first.

    Germany is a developed country with a perfect fusion of classical and modern. A perfect blend of Skyscrapers and classical architecture. some scenery pictures show this.

     

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    In a word, We think this is a very worthy fair, we will continue to attend next year.

    2/18/2020

    Dunpai fireworks Liuyang

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    Dun Pai fireworks will attend 2020 Germany toy fair , make sure you come visit our booth !

    Our spot in hall 11.1 booth C-27, we supply you all CE lines products!

    contact: sales@dpfireworks.com

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    Posted in Uncategorized | Comments Off on Dun Pai fireworks will attend 2020 Germany toy fair , make sure you come visit our booth !

    Fireworks industry facing multiple uncertainties,better be prepared

    For the industry, the recovery after the explosion on Dec. 4th has not been as fast!    In talking with other major exporters at a recent meeting in Liuyang, all confirmed that these critical months of Dec and Jan have been largely lost with both production and shipping being greatly reduced vs previous years.  While December & January typically does not feel like fireworks season for those of you selling on July 4th.   It is actually a critical time for production in China.

    This good news is that this accident happened early and we have some time to try to recover.   The bad news is that even though we have time, the situation is very difficult.    As an example, the factories are all winding down this week for the long Chinese New  Year shutdown.   The holiday should be over mid-February, however, the reality is that it is cold and wet in mid-February.   Most factory workers are older women and only use the income as a supplement, so by choice, many will not return to work until the weather begins to warm again in April.    In addition, there is the annual Beijing government meeting held in mid-March which likely will formally close the factories again.      In addition, Feb & March are very wet and cold in Hunan, so this poses a challenge for production with sub-par performance and  mold issues possible.    And these are just the normal issues in Feb & March!

     

    This year, we face the additional uncertainly of the government final reaction to the Dec. 4th explosion.    An “investigation team” of technocrats have set-up temporary offices in the local hotel and it appears that their goal is to show the big bosses in Beijing that “heads are rolling” and “this  time will be different”.   As an example, the Ministry of Emergency Management in Beijing has set a target for the industry to close another 300 factories and require the new factories be held to a higher level factory standard.    So what are these “standards” exactly?    China’s fireworks laws (GB Standard 2013), much like the USA’s laws, were written many years ago and have countless contradictions and disconnects with the reality of the fireworks industry.    As the investigation team started to review the China laws in detail they have run across several contradictions between USA law and China law.   In the past, the argument was that if an item was legal in the USA, the USA law should be used if the item was transported directly out of China.    However, the Dec 4th accident  was caused by a very large firecracker which supposedly was “legal” in the country it was being exported to.    So now this explosion is being used by the “investigation team” to argue that foreign laws might allow dangerous products to be manufactured and therefore foreign laws should be ignored and only China law followed.

     

    As an example, 1.3g salutes larger than 2 inches have now been banned.   8 Inch shells, even with the improved packing have been banned.    And most recently, USA products like the consumer 3 inch nine shot cakes have reclassified as 1.3g!

     

    All of these examples are “in-progress” interpretations by the investigation team.   They have not made any final rulings yet and we don’t expect anything until after Chinese New Year.    The issue is that if they enforce the China Law as it stands then  there will be many conflicts with traditional USA items (3 inch consumer cakes, 1.3g Salutes, 8 inch shells, etc.).    If they attempt to re-write the China law to remove some of the inconsistencies, then the risk is that the final ruling might take months.   The fear is that if this drags on for months, then many of the smaller factories will simply not be able to reopen.   The process is that factories can apply to the investigation team for approval to reopen at any time.  However, many factories realize that they can’t meet the standard and are choosing to not apply for fear that they might be permanently closed if they are scrutinized.    Even if approved, the rumor is that all factories will have to reduce workers and powder weight by 40% in order to minimize risk.   So basically this means some factories might choose not to open at all for 2020 and those that do will only be able to produce at about half of normal output.  If this happens, then demand will outstrip supply and obviously this will put price pressure on the industry.

     

    To add salt to the wound, Huayang, the biggest fireworks logistics company, stopped shipments via Shanghai on Jan 1st, due to China transportation officials claiming that their shipping paperwork (which they have used for 15 years) was not adequate.      Huayang is trying to update their process and comply, but there are some serious cost implications, and a solution is still being worked on.   We hope this will be resolved before the factories re-open in Feb/March, but it remains a big risk factor as well.

     

    The bottom line is that this season, unlike any others in the past, face multiple uncertainties.     We also had a shipping crisis last season where Shanghai was closed.   But that happened in April and the majority of our products were shipped already.   Also, that crisis did not affect production.   This season, the crisis happened early so it has a much larger potential impact.   Also this season the crisis is effecting both production and shipping.     The hope is that after the long Chinese New Year holiday, Beijing will have moved onto to other issues and the fireworks industry can continue on largely as before.    However, there is also the risk that “this time will be different” and the investigation will drag on for months.   If this happens then the USA July 4th season will be in jeopardy.

     

    As always, our suggestion is getting product out of China sooner, rather than later, is the wise choice.   While it seems like every year the industry keeps pulling off miracles and everything gets shipped, this year could be the exception.   So, please contact us for a detailed update of your production status and review the attached stock list for possible replacements to get your order shipping sooner, rather than later.

     

    All the best.

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    We are very honored to be the supplier of dominator 2019 PGI grand public show !

    Dominator fireworks  USA PGI 2019 grand public show is very successful!

    we are very honored to be the supplier of them! The following video has marked out the product name of effects if you are interested in any products, you are welcomed to contact us at any time!

    Posted in 2019 | Tagged , , , , , | Comments Off on We are very honored to be the supplier of dominator 2019 PGI grand public show !