Regulatory Compliance

Exporting PET Packaging? The Documentation You Can't Afford to Forget

You've found the right supplier. The samples look great. The price is right. You place the order, the goods ship, and then... nothing. Your container sits at the port for two weeks because a single document is missing or incorrect.

This happens more often than you'd think. And it's entirely preventable.

The Core Documents Every Shipment Needs

1. Commercial Invoice

Seems obvious, but errors here cause endless delays. Must include:

  • Accurate product descriptions (not just "PET cans" — specify size, type, lid type)
  • Correct HS codes (PET packaging typically falls under 3923.30 for bottles/flasks or 3923.90 for other containers)
  • Unit prices and total value in the agreed currency
  • Incoterms (FOB, CIF, DDP — this determines who pays for what)

2. Packing List

Details the physical contents of each carton and container. Customs uses this to verify the shipment matches the invoice. Must include carton count, dimensions, gross/net weight, and product breakdown.

3. Certificate of Origin

Proves where the goods were manufactured. Important for:

  • Determining applicable tariffs and trade agreements
  • Meeting country-specific import requirements
  • Qualifying for preferential duty rates under free trade agreements

Food-Contact Specific Documents

If your PET packaging will touch food or beverages, you need additional documentation:

4. Certificate of Compliance (CoC)

States that the material meets the relevant food-contact regulations. For the US, this means FDA 21 CFR 177.1630. For the EU, it's Regulation (EU) 10/2011. The CoC should reference the specific regulation and confirm compliance.

5. Extraction/Migration Test Reports

Lab results showing that the material doesn't release harmful substances under intended use conditions. Should be from an accredited laboratory (SGS, Intertek, TÜV, etc.) and less than 2 years old.

6. Material Safety Data Sheet (MSDS)

Required for shipping purposes. Details the material composition and any safety considerations. Even though PET is generally safe, customs and carriers still require this document.

7. Letter of Guaranty

The manufacturer certifies that the products comply with all applicable regulations. In the US, this letter makes the manufacturer legally responsible for the accuracy of their compliance claims.

Country-Specific Requirements

Different countries have different additional requirements:

MarketKey Requirements
United StatesFDA compliance, FSMA traceability, state-specific regulations (California Prop 65)
European UnionEU 10/2011 compliance, REACH registration, PPWR recycled content targets
United KingdomUK REACH, post-Brexit labeling requirements
Australia/New ZealandFSANZ compliance, AS/NZS recycling standards
CanadaHealth Canada food contact notification, bilingual labeling
Middle EastGSO standards, halal certification for food-contact materials

Common Mistakes That Cause Delays

  1. Wrong HS code: Using a generic code instead of the specific one for your product type. This triggers manual review and delays.
  2. Mismatched values: The invoice value doesn't match the packing list weight or the certificate of origin details.
  3. Expired test reports: Some countries require test reports to be less than 12 or 24 months old.
  4. Missing food-contact docs: Shipping food packaging without CoC or migration test reports. Customs will hold the shipment.
  5. Incorrect Incoterms: Confusion about who's responsible for duties, insurance, and transport costs leads to disputes and delays.

How CHINPK Handles Documentation

We provide a complete documentation package with every export shipment:

  • Commercial invoice and packing list (prepared by our export team)
  • Certificate of Origin (issued by CCPIT)
  • Food-contact CoC and migration test reports (updated annually)
  • Letter of Guaranty
  • MSDS
  • Any market-specific certificates required for your destination

17 years of exporting, zero customs violations. Talk to us about your import requirements, or browse our product range.

Tags

ExportDocumentationCustomsFDAComplianceImport
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