What international certifications are required for exporting packaging materials?

Compliance Challenges of Export Packaging

Exporting packaging materials is not the same as exporting ordinary goods. Packaging often travels abroad as an accessory to the product, or it may be exported as a separate packaging product. In either case, the destination country has specific regulations regarding the safety, environmental friendliness, and recyclability of packaging materials.

In actual operations, the certification issues most frequently encountered by foreign trade packaging companies fall into three categories: restriction of hazardous substances, traceability of forest origins, and sterilization and transportation.

RoHS: Restriction of Hazardous Substances

RoHS is the European Union Directive 2011/65/EU, officially titled the "Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment." Although RoHS targets electrical and electronic products, inks, coatings, and plastic components in packaging materials that are exported together with electronic products are often included in the scope of RoHS review.

The six categories of substances restricted by RoHS: lead ≤1000 ppm, mercury ≤100 ppm, cadmium ≤100 ppm, hexavalent chromium ≤1000 ppm, PBB ≤1000 ppm, PBDE ≤1000 ppm. Inks, plastic films, and composite materials used by packaging and printing enterprises must comply with these limits.

REACH: Registration, Evaluation, and Authorization of Chemicals

REACH is the European Union regulation EC 1907/2006, formally titled the "Regulation concerning the Registration, Evaluation, Authorization and Restriction of Chemicals." Chemical substances in packaging materials such as inks, adhesives, and plastic additives that are produced in quantities exceeding one ton per year in the EU must be registered in accordance with this regulation.

The most direct impact on packaging enterprises is the SVHC (Substances of Very High Concern) list. If the SVHC content in a packaging material exceeds 0.1%, notification to the customer and downstream users is required under REACH. This rule applies to all packaging products exported to the EU and is not limited to the electronics industry.

CE Marking

The CE marking is a mandatory conformity mark for certain products in the European Union, indicating that the product meets the essential requirements of the relevant EU directives. Packaging itself is generally not subject to mandatory CE marking; however, when a product sold with packaging (such as toys or children's products) requires CE marking, the safety of the packaging materials is also taken into account during the assessment.

For pure packaging printing plants, CE is more of a contractual requirement imposed by clients than a legal mandate.

FSC: Forest Source Traceability

When paper or wood-based materials are used in export packaging, FSC certification is a frequently required standard by European and American customers. For a detailed explanation, see the dedicated FSC certification article. Simply put, the absence of FSC does not necessarily prevent exports, but having FSC can significantly enhance customer trust and competitive bidding advantages.

ISPM 15: Phytosanitary Standard for Wood Packaging

ISPM 15 is the international standard for wood packaging issued by the International Plant Protection Convention, with the full title "Guidelines for Regulating Wood Packaging Material in International Trade."

Standard requirements: Wood packaging (such as wooden cases, pallets, and wooden dunnage) must undergo heat treatment or methyl bromide fumigation and bear the IPPC mark. Manufactured wood products (such as plywood, particleboard, and fiberboard) and wood packaging that has been processed to remove its natural wood characteristics (such as wooden boxes and wooden gift boxes) are exempt.

Chinese enterprises exporting wood packaging must apply to the customs authorities for qualification to use the IPPC mark. The mark includes the country code, the manufacturer code, and the treatment code.

FDA: Compliance for Food Contact

Food packaging exported to the United States must comply with the requirements of FDA 21 CFR 170-199. The FDA classifies materials and specifies lists of permitted substances, restrictions, and testing requirements. Corresponding provisions apply to paper, plastics, coatings, metals, and other materials.

For packaging printing companies, the most commonly required documents are the FDA Letter of Compliance or third-party testing reports.

Other Common Target Markets

Japan: Food packaging must comply with the Japan Food Sanitation Law, with a positive list management approach for materials.

Southeast Asia: Most countries (such as Thailand and Malaysia) reference European and American standards, though specific limits and testing items may vary slightly.

Middle East: Countries such as Saudi Arabia and the UAE have local certification requirements for food packaging, including SASO and GCC.

Practical Recommendations

For packaging export companies, the first step is to establish a certification matrix based on the target markets: the European Union (RoHS + REACH + food-related), the United States (FDA + selected UL), and other markets (as specified by the customer).

The second step is to turn the common testing items into an internal standard report library. Frequently required items such as RoHS testing, REACH SVHC declarations, and FDA compliance can be prepared in advance as several general-purpose reports for different materials and processes, avoiding the need to re-test every time a customer requests a quotation.

The third step is to establish compliance documentation for raw material suppliers. The starting point for RoHS, REACH, and FDA compliance lies with upstream raw materials; all that downstream packaging companies can do is use these materials in accordance with the relevant regulations.

For small and medium-sized packaging plants, there is no need to pursue coverage of all certifications from the outset. Configuring 2-3 core certifications based on the target markets of current major customers is sufficient to meet the requirements of most foreign trade orders.