China's 30mm Firework Policy:
How it's Affecting U.S Firework Manufacturing,
Transportation and Sales
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The Chinese Government Is Applying New Standards to U.S. Consumer Fireworks Which Will Affect the Manufacture, Transportation to the U.S. and Potentially the Ability to Sell Inside Consumer Fireworks in the U.S. As of the Fall of 2020, a significant obstacle faces the manufacture and export of traditional consumer fireworks made for America. These are the consumer fireworks sold as fundraising mechanisms by Veterans’ organizations, Boy Scout troops, churches and high school booster clubs at tents and roadside stands over the Fourth of July holiday seasons.
At issue is the application of a certain part of the United Nations “Recommendations on the Transport of Dangerous Goods, Model Regulation, Volume 1, Twenty-first revised edition. Under the guidelines presented by the UN, any multiple tube device (cake) containing tubes with an inside diameter greater than 30mm or 1.2” would be classed as 1.3G (professional display) fireworks unless they were subjected to UN Series 6 testing and were subsequently determined to be 1.4G (consumer fireworks).
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Should such conditions prevail and be fully implemented by the Chinese Government it would have a profoundly negative effect on the manufacture and importation of many 500gram cakes regularly available in the U.S. market today. As of this time there is no final, absolute conclusion on the current situation.
- Historically the country of China has recognized that fireworks being shipped to the United States can be manufactured, classed and transported under the conditions by which the United States categorizes such items. The United States PHMSA/DOT has prescribed construction requirements for fireworks being exported to and imported by American importers which are in place to enhance safety for the manufacturers, transporters, sellers and end users of such products. It is the opinion of the National Fireworks Association (NFA) that U.S. Consumer, 1.4G, UN0336 Fireworks products are the safest in the world.
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This is a Chinese Government ruling, so we need our U.S. Government counterparts to act on our behalf to assist us in Beijing so that further clarity can be passed on to the Changsha authority. This is an international trade issue and the NFA believes this issue could or will have implications even outside our industry in terms of international trade if left unchecked.
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This is Not a Consumer Safety Issue; This is a Transportation Issue.
This does not have anything to do with the function of the firework or it’s safety, this is merely a transportation issue. The NFA and those in the industry are not aware of a singular mass explosion incident during the transportation and/or storage of properly constructed, classed and finished 1.4G fireworks bound for the United States either here or abroad.
This is a critical point and it is well documented throughout the past decades following incidents of fire involving large quantities of stored U.S. 1.4G UN0336 fireworks product imported from China. None of these incidents resulted in deaths or mass explosion incidents. The product is well manufactured and safe from mass explosion hazards.
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Rather than focusing too much on tube size, what is needed is a better mutual (China/US) understanding of:
- What really presents a mass explosion hazard in transportation and storage
- How to prevent a mass explosion hazard in transportation and storage
- The subjectivity of interpretation by independent countries of the UN Recommended Model Regulations and UN testing procedures and how those recommended model regulations are sometimes at odds with themselves
- How to properly construct legal documentation so that business and commerce can continue between international countries and the safety concerns of everyone can be achieved.
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What is the NFA Doing?
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China currently manufactures refrigerators for the U.S. market to U.S. government standards. We believe this sets the precedent for the Chinese government to allow the manufacturing of U.S. 1.4G fireworks under U.S. Consumer Product Safety Commission standards.
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1) The NFA has reached out to PHMSA/USDOT and have requested their assistance in working with China on this issue. This is an international trade issue made by the Chinese Export Authority and the NFA is working with regulators and policymakers to solicit the involvement of the U.S. State Department and the U.S. Trade Representative to assist with the diplomatic side of this issue. This needs to happen.
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2) The NFA is conducting some independent testing to check on the possible compliance of alternatives and we are communicating with manufacturers and group associations in China to aide in the development of solutions for both sides.
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| Background
In December of 2019, a terrible accident happened in China at an unlicensed factory that was manufacturing non-U.S. compliant 1.4G (consumer) fireworks. The tragic result was an accident that led to a significant death toll of workers at the factory. Understandably, the Chinese government swiftly investigated the accident and prosecuted those responsible for the tragedy. Since then there have been a number of changes that China CIQ/Customs (the entity that governs fireworks exports) has implemented to bolster safety protocols. Unfortunately, we believe that their application of the UN recommended standards are being misapplied to U.S. 1.4G consumer fireworks because our U.S. requirements are actually a higher standard, and this has been commonly accepted over many past decades.
The UN recommendations do not address construction methods and specific chemical usage, rather they reference only tube size and individual tube pyrotechnic content. For example, in the U.S. when multiple tube devices, commonly referred to as “cakes” exceed a gross pyrotechnic weight of 200grams, there must be a minimum tube spacing of 12.8mm between all tubes in all directions from each other. This limits the propagation effect of an “explosion” in one tube to continue to the next. This is a significant component of safety. Further, U.S. cakes are commonly constructed to a limit of 500grams of pyrotechnic composition. The UN recommendations do not address these specific construction and gross pyrotechnic device weight issues, rather they define classification based on tube size and pyrotechnic composition per tube alone. The UN recommendations would allow for a cake with inside tube diameters ≤ 30mm where each tube contains a maximum ≤ 25grams per tube of pyrotechnic composition to be manufactured with 100 tubes having no tube spacing. Such a device would be classed as a 1.4G device, but it could contain up to 2,500 grams of pyrotechnic composition and have no tube spacing.
It is the experience of the NFA that such a device would be more dangerous than a 1.4G 9 shot 2.25” 500gram cake manufactured for the U.S. market under U.S. construction requirements. The distinct difference in construction methods and their positive effect on device safety is where we see the crux of the issue.
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