A compliance pack is not one certificate — it is a set of documents covering each component of the pack you buy. Importers collect it before the purchase order, because a missing document stops a shipment at customs, not at the factory. Below: what each market asks for, which component each document must cover, and what a factory may issue.
Quick answer
- A compliance pack is component-level: bottle, closure, liner and decoration each need their own coverage, not one blanket letter.
- ISO 9001 is a factory certificate. It is not a product document and does not substitute for a food-contact or migration report.
- Ask for documents against current lots, not “certificates we hold” — a 2023 report does not cover a 2026 batch.
What is a compliance pack, and what is actually inside it?
Buyers often arrive expecting a single page titled “certificate”. What they receive instead is a layered set, because each layer answers a different question and each one can be requested at a different level of detail.
| Layer | What it proves | Who issues it | When you ask for it |
|---|---|---|---|
| Factory system certificate | The quality management system is audited and current | Certification body, not the factory | Supplier qualification, before samples |
| Audit report | What an auditor observed on a date, at a site | Customer, auditor or third party | Large projects and annual frameworks |
| Resin certificate of analysis | The resin grade in this lot matches its specification | Resin producer, passed through the factory | Every order, per material |
| Food-contact declaration | Components suit food contact under a named framework | Factory, based on supplier declarations | Food, beverage, oral care, pharma |
| Migration test report | A specific sample passed a specific migration test | Accredited laboratory | When the market or the buyer requires it |
| SVHC / restricted-substances statement | Components contain no listed substance above its limit | Factory, based on supplier declarations | EU and UK cosmetic supply chains |
| Recycled-content chain of custody | Post-consumer content is documented from source to pack | Standard owner plus supply-chain partners | Any PCR claim on pack or product |
The distinction that matters most: a factory certificate describes the factory, a product document describes the product. When a supplier sends an ISO certificate in response to a request for a migration report, that is not a refusal — it is a category error, and it is worth naming politely so the request gets answered properly. Our earlier note on which test reports exporters actually need sets out the same distinction from the buyer’s side.
Which documents does each market actually ask for?
Demand differs by market and by what the pack will hold. The table below is what we are asked for, in the order the requests usually arrive.
| Destination market | Most requested documents | Level of detail buyers insist on |
|---|---|---|
| United States | Food-contact declaration for the material and finished pack, resin COA, business-side state requirements | Component-level, named against the pack assembly |
| European Union | EU framework food-contact declaration, migration testing where required, SVHC statement, restricted-substances confirmation | Component-level including closure and liner |
| United Kingdom | UK food-contact documentation, kept distinct from EU documentation | Component-level, current UK requirements |
| Markets outside the EU, US and UK | Certification numbers and audit report copies requested alongside the quotation | Numbers quoted, not described |
| Multi-market brands | The union of the above, per market, with one document set per market | Highest — usually a matrix |
A multi-market brand asking for “documents for Europe, the UK and the US” is not asking three times. They are asking for a matrix: the same component, three different frameworks, three different documents. Suppliers who send one PDF for all three markets usually send the one that is technically weakest.
Does the document have to cover the closure and the liner too?
This is the single most common gap. A buyer requests documentation for “the bottle”, receives a declaration for the bottle, and then discovers that the closure, the pump insert, the liner and the label adhesive were never covered. At product registration or at customs, an uncovered component is still a component in the pack.
| Component | Why it needs its own coverage | What to request |
|---|---|---|
| Bottle body | Direct food-contact surface | Resin COA plus food-contact declaration for the material |
| Closure / cap | Often a different resin, sometimes a different supplier | Declaration naming the closure material and its contact surface |
| Pump assembly | Contains multiple parts — body, insert, stem, spring, ball | Confirmation that the assembled pump is covered, not just the plastic |
| Liner or gasket | Contacts the product continuously; elastomers differ from the bottle resin | Material and food-contact status of the liner itself |
| Induction seal liner | Heat-seal layer sits between product and closure | Construction specification and contact suitability |
| Ink and decoration | Printed surface may contact the product or be a migration pathway | Declaration that decoration is applied outside the contact area, or its own food-contact status |
| Label and adhesive | Often applied by the buyer after filling | Confirm which side is food-contact and who owns that declaration |
Our own position is simple: when a buyer asks for the documents covering “the complete pack”, the answer has to name every component in that pack. If one component is not covered, we say so rather than sending a document that quietly excludes it.
What can a factory legitimately issue, and what can it not?
Factories are issuers for some documents and holders of others. Confusing the two is the fastest way to lose a week.
| Document | Can we issue it? | What we will not do |
|---|---|---|
| ISO 9001:2015 certificate | Yes — issued by a certification body, we hold it and can supply the certificate | Present it as product safety evidence |
| Audit report | We supply reports we hold; third-party audits belong to the auditor | Issue one on a customer’s behalf |
| Resin certificate of analysis | Yes, from the resin producer, passed through for the lot in question | Reissue an old COA against a new lot |
| Food-contact declaration | Yes, against current supplier declarations | Extend it to a component we have not declared |
| Migration test report | We supply existing reports and commission new testing | Describe a report we do not hold |
| SVHC / restricted-substances statement | Yes, as a written declaration per component | Convert a certificate into a substances statement |
| Recycled-content chain of custody | Yes, with a recognised recycled-content standard | Backfill documentation for earlier shipments |
We hold ISO 9001, GRS and SGS-audited production. Everything else in a compliance pack is issued per order against documents on file, or commissioned. We do not label a test report or an audit report as a certification, because a compliance team that finds that out later treats the whole pack as unreliable. The four documents that carry the most weight are set out in our resin quality checklist, and the market-by-market version lives in the export compliance map.
What did buyers actually ask us?
Real questions from inquiries we handled. Company names, countries and order quantities are removed — those are our customers’ business, not ours to publish.
“Please confirm whether you can provide these documents for the complete components, including the bottle, the roller ball, the housing and insert, the cap, and any other components.” — product development company, North America
“Please include certification numbers or audit report copies with your quote, rather than a general description of what you hold.” — consumer product innovation company
“Before sharing the detailed design and technical documentation, we would prefer to have an NDA in place. Could you send us your standard NDA for review?” — food brand, Europe
“This would be used for a drink, so we need the appropriate food-contact documentation for the material and for the finished packaging.” — beverage startup, Europe
Notice what is absent from all four: nobody asked for our most impressive document. They asked for coverage that matches their own pack and their own market.
What are the three mistakes we see most often?
1. Accepting a factory certificate in place of a product document. ISO 9001 tells a buyer that your quality system is audited. It says nothing about the resin in their bottle. When the request goes to a compliance consultant, a system certificate in the pack reads as a non-answer, and it delays the order by a week.
2. Asking for “certificates” without naming components. A declaration for the bottle does not cover the pump insert, the spring or the liner. Ask component by component, in writing, and get the answer in the same form. The cost of asking precisely is one email; the cost of asking vaguely is a registration delay.
3. Treating the document pack as a once-off. Formulas change, suppliers change, and recycled-content claims carry their own chain of custody that expires and renews separately. A compliance pack should be requested at each reorder, not filed once and reused for years.
What to send your supplier so the document set comes back complete
Send this list with the first inquiry, not after the samples arrive:
- Destination market or markets, one line each — do not write “export” or “Europe and America”
- What the pack will hold: food, beverage, cosmetic, oral care, household, car care, or industrial
- Every component in the pack, named: bottle, closure, pump assembly, liner, seal, label
- Whether the closure and liner are supplied by us or by you
- Which framework applies in each market, if you already know it
- Whether you need a migration test report, or a declaration is sufficient
- Whether recycled content is required, and at what percentage
- The version of the pack the documents must cover — a stock model, or a new private mould
- Whether an NDA must be signed before technical documents are shared
- The date the document set must be current as of
If a supplier can answer all ten in one reply, you have a supplier. If they answer four and go quiet on the rest, you already know which of the two you have. If you want the short version of the paper side, the six documents to receive before a bulk order covers what to ask for alongside the commercial terms.
Frequently asked questions
Is an ISO 9001 certificate enough to ship bottles into the EU?
No. ISO 9001:2015 certifies the factory’s quality management system. Import-relevant compliance needs product-level documents: food-contact declarations, resin certificates of analysis and, where required, migration test reports.
What is the difference between a declaration and a test report?
A declaration is a written statement by the supplier, based on their own supply chain. A test report is a laboratory result on a specific sample. Declarations are faster and standard; test reports cost money and time but carry independent evidence.
Do the documents have to cover the pump and the liner?
Yes, if they are part of the pack. The pump contains several components and the liner contacts the product continuously. Ask for coverage component by component rather than accepting a document scoped to the bottle alone.
Can recycled plastic carry a compliance claim?
Yes, with documented chain of custody from post-consumer source through to the finished pack. We work with a recognised recycled-content standard and supply the documentation against the specific order.
Do I need different documents for the UK and the EU?
Yes. The UK maintains its own food-contact requirements. A multi-market brand should request a document set per market rather than one set covering “Europe”.
Will you sign an NDA before I share my design?
Yes, and many buyers ask for it first. Send us your standard NDA for review, or ask for ours. Design files and technical drawings are normally released only after it is in place.
About Shijin Packaging
Shijin Packaging Products Co., Ltd. has been manufacturing plastic packaging in Shenzhen, Huizhou and Guangzhou since 2003. We hold more than 2,000 existing moulds, run ISO 9001, GRS and SGS audited production, and ship roughly 500,000 bottles a day for cosmetic, personal care, household, car care and food-grade customers. Every compliance document we issue is issued per order, against the components in that order.
Send us your document request list — your markets, your pack contents and your application — and we will tell you which documents exist, which need commissioning, and which do not apply to your pack, before you place an order.