When exporting products to the European Union, we often focus on the product itself: material, safety tests, food-contact compliance, certificates, and so on.
But recently, one of our European customers reminded us of something that is easy to overlook:
The packaging also needs attention.
We were working on a silicone rolling pin project. The product itself was quite simple, but the customer asked us to provide information about the packaging because of the EU Packaging and Packaging Waste Regulation (PPWR).
At first, the request looked complicated. The customer mentioned the packaging composition, recycled content, heavy metals, PFAS, and an EU Declaration of Conformity.
So, what should an exporter actually do when receiving a request like this?
Here is how we handled it.
Step 1: Understand What the Customer Really Needs
The first thing we did was not immediately send documents.
We read the customer’s request carefully and broke it down into several specific requirements.
The customer asked for information about:
- Packaging composition
- Recycled content
- Lead, cadmium, mercury and hexavalent chromium
- PFAS, where applicable
- An EU Declaration of Conformity
This was an important lesson for us:
Do not treat “packaging compliance” as one single certificate.
It is usually a combination of information and supporting documents from different packaging suppliers.
Step 2: Break the Packaging Into Components
Our silicone rolling pin was packed with two main packaging components:
1. Paper/cardboard hang tag
2. PVC transparent box
Instead of asking one supplier for everything, we contacted the suppliers responsible for each packaging component.
This made the process much easier.
For the PVC box, the supplier provided a test report issued by CTI.
The report specifically tested the packaging against Article 5(4) of Regulation (EU) 2025/40 and covered four heavy metals:
- Lead (Pb)
- Cadmium (Cd)
- Mercury (Hg)
- Hexavalent Chromium (Cr VI)
The test results showed that all four substances were not detected, and their total concentration was below 100 mg/kg (100 ppm).
So, this report could directly support the customer’s heavy-metal requirement.
Step 3: Check the Recycled Content
The next question was:
Does the packaging contain recycled material?
For the PVC transparent box, the supplier confirmed that it was made from virgin material, meaning the recycled content was 0%.
This information may sound simple, but it is important to get it from the actual packaging supplier rather than guessing.
For the paper hang tag, the supplier’s SGS test report did not specify the recycled content percentage.
Therefore, we did not invent a number.
This is another important lesson for exporters:
If the document does not support a specific claim, do not make the claim yourself.
It is better to write “not specified” and request a separate supplier declaration than to provide an inaccurate percentage.
Step 4: Don’t Confuse Total Fluorine With PFAS
The paperboard test report gave us another useful piece of information.
The SGS report tested Total Fluorine under Article 5(5) of Regulation (EU) 2025/40.
The result was Not Detected (ND) and the conclusion was Pass.
However, the report also stated that a PFAS test was recommended if further confirmation was required.
This is an important technical point.
Total Fluorine and PFAS are not exactly the same thing.
Therefore, we did not simply write “PFAS = ND” in our declaration.
Instead, we reported the actual test result and kept the distinction clear.
For exporters, this is a good habit: always write what the test report actually proves.
Step 5: Check Whether PFAS Is Applicable
The customer’s request also mentioned PFAS for food-contact packaging.
Our PVC transparent box is an outer packaging component and is not intended for direct food contact.
Therefore, we recorded this clearly in our documentation instead of making an unnecessary PFAS claim.
Again, the key is to understand the actual use of the packaging before deciding which documents are relevant.
Step 6: Prepare One Clear Compliance Package
After collecting the information, we organized everything into one packaging compliance document.
For our silicone rolling pin, the package included:
- Packaging composition
- Recycled content information
- Heavy-metal test results
- Total Fluorine information for the paperboard
- Food-contact applicability information
- Supporting laboratory reports
- Supplier information
- Company declaration
This is much more useful to the customer than simply sending several unrelated certificates.
The goal is to create a clear evidence trail:
Packaging supplier → Material information → Test report / declaration → Exporter → EU customer
The customer can then use this information for its own internal packaging compliance process.
What Did We Learn From This Case?
The biggest lesson is that EU compliance is not only about the product.
When exporting to Europe, exporters should start thinking about the product as a complete system:
Product + Packaging + Documentation
A product may have all the necessary certificates, but the customer can still ask questions about the paper card, plastic bag, box, label, adhesive, or other packaging components.
Therefore, it is a good idea to build a packaging information database for regular products.
For each packaging component, we can record:
- Material
- Material composition
- Recycled content
- Relevant test reports
- Supplier declarations
- Food-contact status
- Applicable regulatory requirements
This can save a lot of time when another EU customer asks similar questions.
Final Thoughts
At first, our customer’s PPWR request looked like a complicated regulatory task.
After breaking it down, however, it became much more manageable.
We did not need to start from zero.
We simply needed to ask:
What is the packaging made of?
Does it contain recycled material?
What test reports are available?
Which requirements actually apply to this packaging?
Can every statement we make be supported by a document?
For international sales teams, this is perhaps the most practical way to deal with new compliance requirements.
Don’t be afraid of a long compliance request.
Break it down, collect the evidence, check what each document actually proves, and then build the complete picture.
That is how compliance becomes part of good export service—not just another pile of paperwork.
