Last updated: 1 September 2026.
Quick answer: Food-grade and cosmetic-grade are two different regulatory lanes, not two quality levels. Food contact is governed by frameworks such as EU Regulation No 10/2011 and the FDA food-contact programme in the US; cosmetics are governed by EC 1223/2009 in the EU and the MoCRA framework in the US. A bottle can pass one and not the other, because the migration limits and the substances of concern differ. What you actually need is a Declaration of Compliance naming the right lane, backed by per-lot traceability.
A bottle that holds lotion is not automatically safe for a food or supplement product. Grade, regulation and documentation differ. Here is what exporters to the US and EU need to know.
What ‘grade’ means
Food-grade resins meet FDA or EC food-contact rules; cosmetic-grade meets cosmetic regulations. They are different compliance paths with different testing and documentation.
Why it matters for export
Mis-declaring grade risks customs holds and recalls. Document the resin and any migration testing so the shipment clears and the claim is defensible.
Practical rule
If the product touches the mouth or is ingested, specify food-grade resin with a compliant closure. Otherwise cosmetic-grade is the correct, lower-cost path.
Related: cosmetic bottles, our factory.
Compliance note: Food-contact bottles must clear migration limits. Shijin food-grade PET and HDPE comply with EU 10/2011 and US FDA 21 CFR requirements, with material certificates and migration-test summaries available on request.
Two different compliance paths
“Food-grade” and “cosmetic-grade” are separate regulatory paths, not a quality ranking. Food-grade resins comply with FDA 21 CFR or EU 10/2011 food-contact rules and carry migration testing; cosmetic-grade resins meet cosmetic regulations, which govern the container’s contact with skin rather than ingestion. A lotion bottle is not automatically safe to hold a food or supplement.
The practical rule: if the product touches the mouth or is ingested, specify food-grade resin with a compliant closure. Otherwise, cosmetic-grade is the correct and lower-cost path — and mis-declaring grade risks customs holds and recalls.
Supplements sit in the food lane
Supplements and nutraceuticals sit in the food lane, not cosmetics, so their bottles need food-contact documentation on top of the moisture-barrier and closure choices. A vitamin bottle is typically HDPE for moisture resistance plus a food-grade certificate, while a lotion bottle only needs cosmetic-grade compliance.
Knowing which lane the product occupies is the first decision, because it sets the entire documentation path — and mixing the two is the fastest route to a customs hold or a failed audit.
Documenting grade for export
- Keep the resin food-contact compliance (FDA or EC) and, where relevant, the migration test report in your technical file.
- Match the closure and liner to the same grade — a food-grade bottle with a non-compliant cap is still non-compliant.
- Declare the grade in writing on the commercial documents so the claim survives audit.
- For supplements, confirm the moisture barrier (HDPE for tablets) on top of the food-contact grade.
For an exporter, documenting grade correctly is what keeps a shipment moving through customs and the claim defensible downstream.
What to request per batch, not per supplier
A supplier-level certificate is a starting point; what protects you at customs and in a retailer audit is documentation tied to the batch in your warehouse. Four documents, and the order matters:
| Document | What it proves | Why it is not optional |
|---|---|---|
| Declaration of Compliance (DoC) | The material complies with a named regulation, for named contact conditions | It is the document regulators and retailers ask for first |
| Migration test report | Overall migration and specific migration measured under defined simulants and conditions | A DoC without test data behind it is an assertion |
| Per-lot COA | MFI or IV, density, and additive package for that resin lot | Proves the resin was not silently substituted |
| Traceability record | Resin lot → work order → carton code, in both directions | Turns a recall from a full withdrawal into a targeted one |
The practical test: ask your supplier to send these four for a shipment that left three months ago. A supplier with real systems produces them in a day. A trading company has to go and ask the factory, and the answers come back incomplete or generic.
One more distinction worth internalising — overall migration limit caps the total mass of all substances that migrate out of the material (commonly 10 mg/dm² or 60 mg/kg of simulant under EU rules for plastics), while specific migration limits cap individual named substances. A material can pass overall migration and still fail a specific limit for a particular additive or a primary aromatic amine. Both appear on a competent test report.
Related reading: recycled content and compliance, resin selection, and our quality documentation page, hot-fill packaging hub, and per-lot COA and migration testing.
Frequently Asked Questions
Can a cosmetic bottle hold a food product?
Only if it is specified food-grade with the right documentation — do not assume a cosmetic-grade bottle is food-safe.
What documents prove grade?
Resin food-contact compliance (FDA/EC) and, where relevant, migration test reports from the material supplier.
Can a cosmetic bottle hold a food product?
Only if it is specified food-grade with the right documentation. Do not assume a cosmetic-grade bottle is food-safe — they are different compliance paths.
What proves a bottle’s grade?
The resin’s food-contact compliance (FDA 21 CFR or EU 10/2011) plus, where relevant, a migration test report from the material supplier.
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