BASE-CBCGDF Submitted ThreeSuggestions on the Implementation Measures for Customs Risk Management (Draft for Comments)

Recently, the General Administration of Customs of the People’s Republic of China issued a notice to solicit public opinions on the Implementation Measures for Customs Risk Management (Draft for Comments). The Biological and Scientific Ethics Committee of China Biodiversity Conservation and Green Development Foundation (BASE-CBCGDF) actively responded to the call, and after careful study, put forward the following three suggestions:

(Photo:General Administration of Customs of the People’s Republic of China )

(1) It is recommended to list “invasive alien species” separately.

Invasive alien species is not listed in the full text. In view of the huge harm and far-reaching impact caused by invasive alien species (such as the event of draining the lake to catch alligator gar in the summer of 2022), it is recommended to explicitly list it as an important task of risk management.

(2) It is suggested to add a new paragraph to Article 8 (Information Collection Channels on Customs Risk Management) to expand information channels (especially the international conventions that China is already implementing), and make good use of the existing information resources of these channels to improve customs risk management in China. It is recommended that the following text be listed as a single paragraph:

To obtain risk information from public information platforms and public databases of international conventions, such as the Convention on Biological Diversity and its protocols and information sharing mechanisms, the Convention on International Trade in Endangered Species of Wild Fauna and Flora, the International Convention on the Control and Management of Ships’ Ballast Water and Sediments, relevant international organizations such as the Food and Agriculture Organization of the United Nations, etc..

BASE-CBCGDF’s 3 suggestions on the Implementation Measures for Customs Risk Management (Draft for Comments) were successfully submitted on January 25, 2023.

(3) It is recommended in the section 4 to clearly establish a “whistleblower” system, and reward and strictly protect meritorious personnel who report serious violations of laws and regulations and major risks and hidden dangers, unblock the supervision channels of the masses, integrate and optimize the functions of the government complaint and reporting platform. In this way, the cost of government supervision can be greatly reduced.

Original Chinese Article:

Translator: Daisy

Checked by Sara

Editor: Maggie

Contact:; +8617319454776


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