Export Documents for PP Food Containers: The Complete Set
The six, in the order they are needed
| Document | Issued by | Purpose | Common failure |
|---|---|---|---|
| Commercial invoice | seller | customs value | vague description, no HS code |
| Packing list | seller | carton count, weight, dimensions | does not match the B/L |
| Bill of lading | carrier | title to goods | consignee details wrong |
| Certificate of origin | chamber of commerce / CCPIT | duty rate, trade agreement | not requested until too late |
| Food-contact declaration | manufacturer | regulatory compliance | generic, no SKU list |
| Test reports | accredited lab | migration, heavy metals | expired or wrong market |
The description problem
Customs classification for PP food containers sits in two headings, and the choice changes the duty:
| HS code | Description | Typical use |
|---|---|---|
| 3923.10 | boxes, cases, crates of plastics | transport packaging |
| 3924.10 | tableware and kitchenware of plastics | food service containers |
Most PP lunch boxes and food containers go under 3924.10 — they are tableware, not transport packaging. A sauce cup can go either way depending on how the invoice describes it. Getting this wrong invites a reclassification, a duty adjustment and a delay.
The invoice description should read like this, not "plastic products":
PP food container, model PF-SQ750, 750 ml, food-grade polypropylene, 300 pcs/carton, HS 3924.10
The food-contact declaration
This is the document buyers actually care about, and the one suppliers most often fake. It must state:
- The material (PP, food-grade, virgin resin)
- The regulation it complies with (EU 10/2011, FDA 21 CFR 177.1520, or both)
- The SKU list it covers — by model number
- The issuing entity, dated and signed
A declaration that says "our products comply with FDA" with no model list is not usable. A buyer forwarding it to a retailer will be asked which items it covers, and the answer will be "all of them", which is not an answer.
Test reports: what is actually required
| Market | Test | Validity |
|---|---|---|
| EU | overall migration (OM), specific migration for relevant monomers | typically 5 years, or per batch |
| EU | heavy metals, primary aromatic amines | per material |
| US | FDA 21 CFR 177.1520 compliance, often via resin supplier letter | per resin grade |
| Germany | LFGB | per material |
| Japan | Food Sanitation Act | per material |
One report does not cover all markets. A Chinese lab report for EU migration does not satisfy a Japanese buyer, and a US resin letter does not satisfy an EU retailer. Check the destination before the order, not after.
Certificate of origin and trade agreements
For ASEAN, RCEP and other preferential arrangements, a Form E or RCEP certificate reduces duty. It must be applied for before shipment — retroactive issuance is possible in some schemes and painful in all of them.
If your buyer asks for a specific form, confirm the factory is registered for it. Not every exporter is.
The mismatch that causes most delays
Packing list says 1,395 cartons; bill of lading says 1,400. Container is held while three parties email each other.
Prevention is simple: issue the packing list from the actual loading tally, not from the production plan. The tally is taken at the container door; the plan is a forecast.
FAQ
Do PP containers need an MSDS? No — PP is an article, not a chemical substance, and food containers are not dangerous goods. Some forwarders ask for a non-haz declaration; that is a one-page statement, not an MSDS.
Is a phytosanitary certificate needed? No, unless the packaging includes solid wood (not plywood, not pallets with an IPPC stamp). Cartons and pallets do not need it.
Can you ship under buyer's nominated forwarder? Yes, under FOB. Under CIF we choose, and we will still accept the buyer's forwarder if the rate is workable.
What if the test report expires mid-contract? The report covers the material and the test date, not the shipment date. In practice, buyers accept a report within 3–5 years. If your market requires per-batch testing, budget for it in the unit price.
Related reading
- How to Import PP Containers from China: 8 Steps
- LCL vs 20GP vs 40HQ: Choosing the Right Load
- From Inquiry to First Order: What Happens After You Ask for a Price
Models covered on this site: 2500 ml PF-RW2500 · 950 ml PF-GG950 · 1000 ml PF-SQ1000S · see all models in this category.
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