Packaging Compliance Labs

What is a Packaging Compliance Lab?

A packaging compliance lab refers to a professional organization with recognized qualifications (such as ISO/IEC 17025, CNAS, CMA, etc.) that provides regulatory compliance verification, hazardous substance testing, and transportation simulation testing for packaging materials, packaging units, and printing accessories.

Regulatory Requirements for Exporting Packaging to Europe and the US

European Union: PPWR

The EU Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) came into force in February 2025 and will become fully applicable starting August 12, 2026, directly replacing the older 94/62/EC Directive.

Chemical Compliance Requirements

Note: A rohs report cannot replace the PPWR heavy metal test. The testing logics are different, and customs will not accept it.

Food Contact Packaging Requirements

1.European Union: EU 10/2011 (Overall Migration 10mg/dm2, Specific Migration SML) + EC 1935/2004 Framework

2.United States: FDA 21 CFR (Chapter 176 for Paper, Chapter 177 for Polymers)

3.Additional Risk Substances: Mineral oils (MOSH/MOAH), PFAS, BPA

US Market

FDA: Food contact material compliance (not a "certificate system", supported by enterprise self-declarations + test reports).

TPCH: Toxics in Packaging Clearinghouse in multiple US states (heavy metals + PFAS + phthalates).

California SB 54 / Prop 65: Plastic reduction and warning substance disclosure.

ISTA 6-Amazon: General testing for e-commerce logistics packaging.

Labeling and EPR

1.Material hazardous substance test reports

2.Design for recycling and evaluation documents

3.Packaging marking / material coding (e.g., GB/T 18455, PPWR unified labeling)

4.EPR registration number and annual declaration records

Product Testing and Standard Requirements

Chemical and Material Testing

1.Four Heavy Metals: ICP-OES / ICP-MS, split by homogeneous material (substrate, ink, glue, coating tested separately).

2.PFAS Screening: Total fluorine first; if exceeded, separate into organic/inorganic fluorine.

3.Food Contact Migration: Overall Migration Limit (OML), Specific Migration Limit (SML), NIAS non-intentionally added substances screening.

4.Supporting Regulations: REACH XVII, SVHC, POPs, LFGB, DGCCRF, TSCA.

Physical and Transportation Simulation Testing

Tip: For e-commerce packaging, it is recommended to directly perform the ISTA 3A + 6-Amazon combination, which covers both express delivery chains and platform factory audits simultaneously.

Recyclability and Environmental Claim Testing

1.Recyclability classification (Class A/B/C, based on EN 13430, CEPI methods)

2.PCR (Post-Consumer Recycled) content quantification

3.Degradable / Compostable: EN 13432, ASTM D6400, ISO 14855

4.Anti-"Greenwashing": Degradable claims must have corresponding certificates; printing just a leaf icon is not allowed.

Which Products Need Packaging Compliance?

Conclusion: As long as it is sold to Europe or the US with packaging, it can hardly be exempted.

According to PPWR classification, it mainly covers four types of packaging:

Sales Packaging (Primary Packaging)

Parts directly in contact with products:

1.Food & Beverage: Bottles, cans, bags, Tetra Paks, baking paper, takeout boxes.

2.Cosmetics & Personal Care: Cream jars, tubes, perfume boxes, makeup trays.

3.3C Electronics: Phone boxes, blister trays, earphone cases, charger color boxes.

4.Pharmaceuticals & Healthcare: Blister aluminum-plastic sheets, medicine bottles, health supplement jars.

5.Apparel & Toys: Hangtags, plastic bags, shoe boxes, stationery set boxes.

Grouped Packaging (Secondary Packaging)

1.Six-pack shrink films, gift boxes, set packaging liners, middle boxes.

2.Outer tray + partition structures for multi-piece products.

Transport Packaging (Tertiary Packaging)

1.Express cardboard boxes, bubble bags, stretch film, EPE/EPS cushioning.

2.Wooden boxes, pallets, strapping bands, tamper-evident plastic seals.

3.Cross-border e-commerce FBA warehouse packaging.

Service Packaging

1.Catering takeaway cups, coffee lids, disposable tableware.

2.On-site portioning bags in supermarkets.

High-Risk Category Focus

FAQ

Are test items the same for food contact packaging and ordinary packaging?

No. Ordinary packaging mainly focuses on PPWR heavy metals and PFAS, while food contact packaging requires additional specialized tests such as overall migration, specific migration, BPA, and mineral oils.

Is PPWR required for exporting to the United States?

No. PPWR is not required for the US, but you must satisfy FDA 21 CFR, TPCH (state-level), California SB 54, Prop 65, and e-commerce platform ISTA transport tests.

How long does a set of packaging compliance tests take, and how much does it cost?

1.Physical & transport tests: Typically 3–5 working days.

2.Chemical test items: Typically 5–7 working days.

3.Full solutions: Depending on material complexity, a single SKU usually ranges between 1,000–3,000 USD.

Do inks, glues, and coatings need to be tested separately?

Yes. PPWR requires testing by "homogeneous component". Different colored inks, glue layers, and coatings cannot be mixed together; otherwise, the test report will not be accepted.

If a small seller only sells on Amazon, is packaging compliance still necessary?

Yes. Amazon Europe has incorporated EPR registration numbers into its system verification. Missing PPWR-related documents will directly restrict your sales.

Can I print the recyclable symbol on my own?

You can print symbols, but not arbitrarily. The marking must match the actual material composition. Claims of being "degradable / recyclable" must be supported by corresponding evaluations and certificates; otherwise, it carries the risk of greenwashing.