Packaging Certification

Packaging Inspection Report: 3 Types of Genuine Classifications: Printing Factory-Provided QS / CoA / Commissioned Inspection — Which One Does the Client Need to Avoid Compliance Risks?

📅 2026-10-18 ✍️ Wuxi Lexiang Printing & Packaging ⏱ 3min read

💡 💡 At a Glance

Printing factories are often asked by customers to provide inspection reports, but QS reports, CoA reports, and third-party commissioned inspection reports are fundamentally different: a QS report refers to the factory production license, a CoA certifies the quality of a specific production batch, and a third-party inspection report presents compliance testing results. A printing factory cannot affix its own seal to a QS report, but it may affix a CoA seal; third-party testing must be commissioned to a CMA / CNAS-accredited laboratory. This article uses 3 real customer cases to explain when a printing factory should decline a request, how much it should charge, and when it should recommend that the customer arrange testing independently.

Last November, the owner of a mooncake gift box factory in Wuxi slapped a report printed with "Jiangsu XX Testing Technology Co., Ltd." on the desk and asked me, "Mr. Zhang, our customer says the report we used before was fake and wants us to issue a new QS report; otherwise, they won't place any orders next year. Can you just put a stamp on it?"

I looked at the report cover—it was a Commissioned Testing Report for Food Contact Materials issued to our company by the customer last year, complete with the CMA seal, CMA number, tester’s signature, and test date. However, what the customer referred to as the "QS report" meant the periodic supervision inspection report accompanying the factory production license (SC certificate), organized by the local market regulation authorities and conducted once a year before license renewal. These two documents are entirely different.

This is not an isolated case. Today, among the three food packaging factories in Wuxi, two have received requests from customers stating that the “report is incorrect,” and the reason in both cases is a failure to distinguish clearly between different types of reports. Let me clarify this issue: which type of report stamp the printing factory is authorized to affix, which report the customer needs for compliance, and the information gap between these two points—this is the aspect most likely to be overlooked in packaging certification.

Category 1: The QS (SC) Supervisory Inspection Report—Where Printing Plants Most Commonly Fail

QS stands for Food Production License. It was renamed SC in 2015, but customers still commonly refer to it as QS. This report is not issued with the printer’s own seal, nor can it be obtained by the customer independently. It is a type inspection report organized by the local market supervision authority when a food packaging customer applies for a production license.

Some customers ask the printing plant to “show us your QS report”—this is the wrong question to ask. As the producer of the packaging, the printing plant holds only a “Food Packaging Material Production License,” which is separate from the customer’s “Food” Production License. The printing plant holds an “Industrial Product Production License” (including subdivisions for plastic food packaging, paper packaging, glass packaging, etc.), but the samples tested for the printing plant’s license are packaging bags, boxes, and plastic containers produced by the printing plant itself; it does not test the food itself on the customer’s behalf.

Where are printing press owners most likely to fail? Three mistakes:

  • Error 1: The customer requested a "QS report" from the printing plant, but the plant showed the customer its own SC report. The customer rejected it because the report listed the printing plant's product model, and the customer's product specifications were different.
  • Error 2: The customer asked the printing plant to issue an SC report on the customer's behalf. Unaware that it was not qualified to do so, the printing plant accepted the testing fee and was subsequently sued by the customer for fraud.
  • Error 3: The customer was producing food packaging for the first time and instructed the printing factory to proceed without having obtained an SC certification. The printing factory did not verify the customer’s qualifications before issuing the order, and as a result, when the customer was inspected by the market supervision administration, the printing factory was held jointly accountable.
  • What should the printing factory do here? Check the customer's SC license and verify whether the “Food Category” listed on the SC license corresponds to the category of packaging to be produced (pastries, mooncakes, chocolate, candy, meat products, pickled vegetables, etc.). Check the SC license’s validity period. If the customer’s license has expired or they do not have one at all, the printing factory must reject the order outright—this is not excessive caution. Under the “joint accountability” mechanism introduced by the State Administration for Market Regulation in 2023, the printing factory, as an upstream supplier, must also sign a “Supply Confirmation” and enter it into the system. If a problem occurs, both the customer and the printing factory will be penalized.

    Category II: CoA Report (Batch Product Quality Certificate) — the printer can issue it, but within certain limits

    CoA is short for Certificate of Analysis. It serves as proof that a given batch of products meets the factory release standards and is attached to the batch when it leaves the factory. In the food packaging industry, a CoA typically contains 5 basic categories of information:

  • Overall dimensions (L × W × H mm, grammage g)
  • Material (white cardboard / gray board / corrugated grade)
  • Print color difference (ΔE ≤ 3.0 or as customized by the brand)
  • Physical properties (compression resistance / burst strength / puncture resistance / edge crush strength)
  • Sanitation indicators (microorganisms / evaporation residue / heavy metal migration)
  • Can the printing plant affix its own quality inspection stamp to this report? Whether it should do so depends on two conditions:

  • The quality inspection departments of printing factories are capable of conducting these tests—for example, appearance and dimensions, grammage, and print color variation. Most printing factories can perform these tests; however, physical properties (compression resistance / burst strength) require standard laboratory equipment (electronic universal testing machines), while hygiene indicators require an incubator and relevant chemical analysis capabilities. Most small and medium-sized printing factories are unable to perform these tests.
  • Test data on the CoA is accurate and reliable—the most common pitfall for printing plants is for an engineer to deem the color difference acceptable, fill in “OK,” and submit the report. When the customer later takes the CoA for comparison with a national spot check, the data does not match, and the printing plant is placed on the list of untrustworthy entities.
  • Therefore, the reliable approach is: for items the printer can handle, the printer stamps them itself; for items the printer cannot handle, send them to a third-party CMA laboratory for testing. There are two fee arrangements: where the customer does not designate a supplier, the printer adds a 5-15% testing coordination fee to the quotation; where the customer designates a third party, the customer pays the testing fee, and the printer charges a sample-submission coordination fee of 200-500 yuan/batch.

    Here is a real case for comparison. In October 2025, a customer in Suzhou producing flexible packaging for pickled and cured foods sent me a CoA stamped with the printing factory’s quality inspection seal, but the compression resistance data consisted only of the words “passed,” handwritten by the printing factory’s engineer. I conducted a secondary inspection for the customer and sent the samples to a CMA laboratory for testing. The burst strength was found to be 18% below the standard—the printing factory’s engineer had written “passed” based purely on feel. This incident caused the customer approximately RMB 72,000 in return and rework costs for 20,000 units. The printing factory ultimately compensated only RMB 4,000, but the customer moved all orders elsewhere starting the following year.

    Type 3: Third-party entrusted inspection report—the printing factory assists with sample submission, but its official seal is not affixed

    A third-party entrusted inspection report refers to a compliance test conducted by a CMA / CNAS-accredited laboratory designated by the customer or recommended by the printing plant. Among the three types of reports, it carries the greatest legal validity, and it is the type of report that the printing plant should be least likely to stamp with its own seal.

    What the printing factory needs to do is:

  • Sample submission without arbitrarily designating a laboratory——For food-contact materials, samples must be sent to a CMA-accredited laboratory for GB 4806 series testing; for cosmetic packaging, samples must be sent to a CMA-accredited laboratory for GB/T 29604 series testing; and for primary medical device packaging, samples must be sent to a CMA-accredited laboratory for GB/T 19633 / ISO 11607 series testing. The standards laboratories corresponding to these testing items have nationally mandated qualifications. If the printing plant arbitrarily selects a "testing company," the report it issues will not be recognized by the regulatory authorities if submitted by the customer.
  • Sample preparation must comply with requirements—When packaging materials are submitted for inspection, the products delivered by the printing factory must be bulk production samples (not pre-production samples), must be made from the same batch of raw materials used for the bulk production, and must include 5 times the required quantity as backup for retesting.
  • The original report is retained by the client—although the third-party report is issued in the name of the printer’s products, its legal validity belongs to the commissioning party (the client). The report bears the CMA seal, CNAS seal, and the inspector’s signature seal. The printer’s seal must never be affixed. The printer may retain a copy for quality records.
  • A customer's willingness to pay for testing indicates that they place value on quality—and such customers should be valued by the printing plant. However, the printing plant should also clarify in advance: the testing cycle for the report typically takes 7-15 working days, while special items such as overall migration and plasticizer screening require 20-30 working days. This means customers must allow at least 1 month from placing the order to receiving the report. The printing plant should include the testing cycle in the contract terms to prevent customers from pressuring the plant to shorten delivery deadlines because they are unwilling to wait.

    How Does a Printing Company Determine Which Version the Client Actually Wants?

    When a customer comes to the printing plant asking for a "test report," the first thing the printing plant owner does is not look for a report template, but ask the customer three questions:

  • Which food subcategory (or cosmetics/medical devices) do you specialize in?—This determines whether to follow SC registration, cosmetics filing, or medical device filing;
  • Who will be reviewing this report? — For listing on retail shelves, market supervision spot checks, customs export inspections, or brand compliance reviews, each purpose requires a different report type and set of testing items;
  • Show me the customer's SC certificate / Cosmetics Production License / Medical Device Manufacturing License number—no certificate, no order.
  • If the packaging is for listing on retail channels (supermarkets, convenience stores, or e-commerce platforms), the printer can provide a CoA report and submit samples to a third party for a GB 4806 report. If it is for the customer’s own SC annual inspection, the printer does not need to provide any reports, as the customer must handle the application independently. If it is for an export customer, the applicable standards depend on the destination country (FDA / EU 1935 / KFDA / JP Food Sanitation Act, etc.). The printer is responsible for sample submission and data support, while the customer is responsible for the entire compliance process, as this is beyond the printer’s control.

    If the print shop owner has no clear understanding of this process, orders will inevitably be missed, or the customer will run into difficulties and make unreasonable demands. I recommend that every print shop create a "classification correspondence table for inspection reports" and post it in the sales office or include it as part of the customer onboarding SOP. Within 3 minutes, customers can understand for themselves which report to request and from whom. This is not embarrassing; on the contrary, it demonstrates the print shop’s professionalism.

    Real Pricing Figures from These 3 Types of Report Printing Companies

    Show the print shop owner a realistic quotation range so that they have a clear idea when preparing a quote:

  • In-house CoA at the printing plant: 200-600 yuan per batch (including labor and basic testing consumables), depending on the number of report items and whether the printing plant routinely conducts the tests;
  • Third-party CMA / CNAS testing: RMB 800-2500 per item (approximately RMB 1500 for one item, such as GB 4806.7 evaporation residue), and RMB 4000-12000 for the full test package (complete testing for food-contact materials);
  • Type Inspection Report (supervisory inspection category): The customer handles this independently, and the printing plant charges no fee—the printing plant should not even tell the customer how much this costs;
  • Sample Submission Coordination Service Fee: The printing plant charges 200-500 yuan per batch (including sample preparation, data transfer, and report handover)—this is reasonable service revenue for the printing plant and does not constitute an "additional charge."
  • If the customer proactively requests that the "testing fees be paid on their behalf," this should be included in the quotation rather than promised verbally, to avoid disputes later. If the customer says, "We will provide the test reports in the future, so deduct the testing fees from the printing factory's quotation"—the printing factory may agree, but the contract terms must clearly specify that the test reports provided by the customer must cover the corresponding models of the products undertaken by the printing factory, must be issued by a CMA / CNAS-accredited laboratory, and must include the full set of compliance items potentially required by the printing factory. Otherwise, the reports provided by the customer shall be deemed insufficient, and the printing factory shall not be responsible for any resulting compliance risks.

    Further Reading

  • 6 Types of Mandatory Food Packaging Labels: Ingredients / Allergens / Shelf Life / Nutrition Facts / Net Content / Place of Origin—3 Pitfalls Prin shops Most Often Overlook
  • Hands-On Testing for Food Contact Packaging GB 4806: 5 Commonly Problematic Test Items + 3 Remedies for Failures
  • 3 Types of Rules for Realistically Sharing Gift Box Sample Costs
  • 6 Types of Real Actions by Packaging Box Suppliers During Factory Audits
  • Frequently Asked Questions (FAQ)

    #QS #CoA

    FAQ

    Do QS reports and CoA reports carry the same legal effect?

    Not at all. A QS (SC) report is the type inspection report paired with the food production license, serving as the basis for the market regulation bureau to issue the license, and carries the highest legal effect. A CoA is a quality certificate issued by the printer for each batch, is a commercial act, and the quality responsibility subject is the printer itself. The two cannot replace each other, and the report a client needs depends on their intended use.

    If a printer has no QS report, can they still do food packaging?

    Yes. But what the printer needs is not a food QS (SC) certificate, but rather an industrial product production license for the printer's own product category (such as food-use plastic packaging, paper packaging, glass containers, etc.). The food QS (SC) certificate belongs to the client; the printer only needs to verify the client's qualification.

    Can a printer issue a third-party CMA test report directly?

    No. Third-party CMA / CNAS reports must be issued by an accredited laboratory, and any seal from the printer has no legal effect. If the printer stamps its own report with a CMA seal and gives it to the client, that constitutes forging qualifications, punishable by a 5-15 million RMB fine and, in serious cases, revocation of the business license.

    Does a printer provide CoA reports for free every time?

    No. In-house printer CoAs typically cost 200-600 RMB per batch, depending on the number of test items, client requirements, and the printer's testing capability. If the printer treats CoA as a free gift, clients may instead suspect the genuineness of the printer's quality commitment.

    Who should reasonably pay for third-party test report fees?

    Generally the client, depending on use case. For brand clients (requiring a CMA report for every batch), testing fees are paid by the client, and the printer only charges a sample coordination fee. If it's testing the printer recommends when a client places their first order, the printer can add a 5-15% testing handling fee to the quote, but this must be clearly stated in the contract terms.

    If a client is doing food packaging for the first time and has no SC certificate, should the printer accept the order?

    In principle, no. The market regulation bureau has a joint accountability mechanism for food packaging suppliers, so if a client without an SC certificate is found in violation during a spot check, the printer as upstream is also penalized. The printer is advised to refer the client to the SC certificate application process and resume supply talks once the client obtains the certificate.

    Can a single test report be reused across multiple clients?

    No. CMA / CNAS reports correspond to a specific submitted sample's model, specifications, client, and production batch. Using client A's report for client B's product constitutes compliance fraud. Each client's each product should have independent testing, with at least one annual retest.

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