Export Documents for PP Food Containers: The Complete Set

Export Documents for PP Food Containers: The Complete Set

The six, in the order they are needed

DocumentIssued byPurposeCommon failure
Commercial invoicesellercustoms valuevague description, no HS code
Packing listsellercarton count, weight, dimensionsdoes not match the B/L
Bill of ladingcarriertitle to goodsconsignee details wrong
Certificate of originchamber of commerce / CCPITduty rate, trade agreementnot requested until too late
Food-contact declarationmanufacturerregulatory compliancegeneric, no SKU list
Test reportsaccredited labmigration, heavy metalsexpired or wrong market

The description problem

Customs classification for PP food containers sits in two headings, and the choice changes the duty:

HS codeDescriptionTypical use
3923.10boxes, cases, crates of plasticstransport packaging
3924.10tableware and kitchenware of plasticsfood 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

MarketTestValidity
EUoverall migration (OM), specific migration for relevant monomerstypically 5 years, or per batch
EUheavy metals, primary aromatic aminesper material
USFDA 21 CFR 177.1520 compliance, often via resin supplier letterper resin grade
GermanyLFGBper material
JapanFood Sanitation Actper 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

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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