Quick answer: A recycled-content or food-contact claim is only as strong as four documents: a Declaration of Compliance naming the regulation and contact conditions, a migration test report dated within 12 months, a per-lot Certificate of Analysis (MFI or IV, density, ash content), and for recycled resin a GRS Transaction Certificate naming the specific product and percentage. The most common gap is not a missing certificate — it is a certificate at the supplier level where what you need is one at the lot level. A scope certificate says the factory is certified; a transaction certificate says this batch of resin was.
Last updated: 1 September 2026.
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The four documents, and why the order matters
| # | Document | What it proves | Level it must be issued at |
|---|---|---|---|
| 1 | Declaration of Compliance (DoC) | The material complies with a named regulation, for named contact conditions and simulants | Product or material family |
| 2 | Migration test report | Measured overall and specific migration under defined conditions | Material, tested within 12 months |
| 3 | Certificate of Analysis (COA) | MFI or IV, density, ash content, additive package | Per production lot |
| 4 | GRS Transaction Certificate (TC) | This lot of recycled resin was sold under GRS, at a stated percentage | Per purchase lot |
A supplier that can produce documents 1 and 2 but not 3 and 4 has a certification programme, not a quality system. That distinction does not matter until something goes wrong — and then it is the only thing that matters, because 1 and 2 describe what the material should be while 3 and 4 describe what was actually in your cartons.
Certifications: what each one actually covers
Several schemes sound interchangeable and are not. Knowing which one you are being shown prevents a lot of confusion at audit.
| Scheme | Covers | Typical use | What it does not do |
|---|---|---|---|
| GRS (Global Recycled Standard) | Recycled content %, chain of custody, plus social and environmental criteria | Branded cosmetic and personal-care packaging with a public recycled claim | Does not assess migration or food-contact safety |
| RCS (Recycled Claim Standard) | Recycled content % and chain of custody only, without the social/environmental criteria | Cost-sensitive programmes where the content claim is the only requirement | No social or environmental audit |
| SCS Recycled Content | Recycled content verification, often used in North America | US retail programmes | Different chain-of-custody model from GRS |
| EuCertPlast | Certifies the recycler’s process and quality management, European scheme | Sourcing recycled resin where process quality matters | Certifies the recycler, not your finished bottle |
| ISO 9001 | Quality management system of the factory | Baseline supplier qualification | Says nothing about the specific material |
The practical takeaway: the recycled-content certificate and the safety documentation are two separate files. GRS proves the 50%. EU 10/2011 or FDA testing proves the bottle is safe to put product in. A supplier showing you one and implying it covers both is either confused or hoping you are.
Reading a Transaction Certificate
A GRS TC is short, and three fields do all the work:
- Product description and recycled percentage. Must name the material (for example “rPET pellets, 100% post-consumer”) and the percentage. If the percentage is expressed as a range, that is a warning sign.
- Lot / batch numbers and quantity. Must correspond to the resin actually purchased. A TC issued for 20 tonnes when you bought 2 tonnes of a specific lot does not cover your lot.
- Input–output balance. The certificate reconciles recycled input against certified output. If the seller cannot show the TC for the lot they sold you, they are asking you to trust their allocation arithmetic.
Ask for the TC at purchase-lot frequency. An annual certificate is a sales document; a per-lot TC is a compliance document.
Migration testing: the terms you need to read a report
A migration report is only meaningful if you can read three things: the limit applied, the simulant used, and the test conditions.
Overall Migration Limit (OML) caps the total mass of all substances migrating out of the material. Under Regulation (EU) No 10/2011 on plastic food-contact materials, the limit is 10 mg/dm² of contact surface, alternatively expressed as 60 mg/kg of food simulant. This is the headline number on most reports.
Specific Migration Limits (SMLs) cap individual named substances — monomers, additives, certain metals. A material can comfortably pass the OML and still breach an SML for one additive, so a report that only shows the OML is incomplete.
Simulants stand in for the product, and the choice depends on what you are filling:
| Simulant | Represents | Typical cosmetic application |
|---|---|---|
| A — 10% ethanol | Aqueous, hydrophilic | Water-based toners, gels |
| B — 3% acetic acid | Acidic | Low-pH exfoliants, acidic formulations |
| C — 20% ethanol | Alcoholic, up to 20% | Many lotions and serums |
| D1 — 50% ethanol | Alcoholic, and dairy-type emulsions | High-alcohol products, emulsions |
| D2 — vegetable oil / substitutes | Fatty | Oil-based serums, balms, anhydrous products |
| E — Tenax | Dry | Powders |
Test conditions matter as much as the simulant. A常温 ambient fill-and-store product is typically assessed under a long low-temperature condition (commonly cited as 10 days at 40°C), whereas hot-fill or pasteurised products require high-temperature conditions. A report run under the wrong condition is not evidence for your application.
Two further items separate a competent report from a minimal one:
- Primary aromatic amines (PAA). Treated as not-detectable under EU plastics rules, with a detection limit in the order of 0.01 mg/kg per substance. PAA failures are a classic consequence of certain azo colourants and of poorly controlled recycled input.
- NIAS (non-intentionally added substances). Reaction by-products, impurities and degradation products that were never deliberately added. A proper compliance exercise includes a risk assessment covering NIAS, not just the declared formulation — and this is where recycled resin needs the most attention, because the input stream is by definition not fully characterised.
The cosmetic lane is separate
Worth stating plainly, because it trips people up: EC 1223/2009 governs cosmetic products in the EU, and packaging is not a cosmetic ingredient. There is no single EU regulation that sets migration limits for cosmetic packaging per se.
In practice, brand owners hold cosmetic packaging to the food-contact numbers anyway — EU 10/2011 in Europe, and the FDA’s food-contact programme (for example the 21 CFR 177 series, with 177.1630 covering PET and 177.1520 covering olefin polymers) in the US. The reason is pragmatic: food-contact testing is better documented, better understood by retailers, and stricter than anything else available. If your packaging passes as food-contact, the cosmetic argument is already settled.
In the US, cosmetics packaging is also touched by MoCRA, which is primarily about product safety and facility registration rather than packaging migration. Read it as another reason to hold documentation, not as a packaging standard.
The checklist
Use this as a pre-order qualification and as a per-shipment check.
Before you place the order
- Supplier has stated the resin grade designation in writing, not just the polymer name
- Supplier has declared whether the contact layer is prime virgin or contains regrind
- Declaration of Compliance names the regulation and contact conditions applicable to your product
- Migration report is dated within 12 months and covers the right simulant for your formula
- Migration report covers both overall migration and relevant specific migration limits
- If recycled content is claimed: GRS or equivalent scope certificate is current
- Recycled PET intended for contact: the recycling process is approved (EU) or covered by an FDA no-objection letter (US)
- Finished packaging is screened for heavy metals where the destination market requires it
Per shipment
- COA per lot, showing MFI or IV, density, and ash content
- GRS Transaction Certificate per lot (not a photocopy of the annual certificate)
- Lot number on the carton resolves back to a resin lot in the supplier’s records
- Odour check on molded parts from the production lot
- Cross-cut adhesion result for printed parts, recorded per run
- Colour is within the agreed tolerance — and measured against a standard, not against memory
Annually, or when the formula changes
- Compatibility / stability testing with the actual formulation: fill, store at elevated temperature, inspect for stress cracking, panel swelling, discolouration and weight loss
- Re-run migration testing if the resin source or grade changes
- Re-confirm the recycled-content TC chain if the percentage changes
Where this fits in a sourcing decision
None of this documentation replaces the basic commercial checks — it sits on top of them. If you are comparing quotations, our 2026 cosmetic bottle price breakdown covers the cost side, and our virgin versus recycled resin comparison covers the material side. For the recycled-content paperwork specifically, the GRS and PCR buyer’s guide goes deeper on percentages and colour.
Our own documentation set — what we issue per shipment, and which certificates we hold — is listed on the quality page.
Frequently asked questions
Is a GRS certificate proof that a bottle is safe for cosmetic contact?
No. GRS verifies recycled content and chain of custody. It says nothing about migration. You need both the recycled-content supply-chain documentation for the claim and migration testing for the safety case.
How often should migration testing be repeated?
Practically, annually, and immediately whenever the resin grade, the supplier or the formulation changes. Migration is a property of the material in contact with your specific product under specific conditions, so a change on any of those axes invalidates the previous report.
What is the difference between a scope certificate and a transaction certificate?
A scope certificate says the supplier has been audited and is certified to sell GRS-certified material. A transaction certificate says a specific lot, of a specific quantity, at a specific recycled percentage, was actually sold under the scheme. Only the second one covers the resin in your warehouse.
Does 10 mg/dm² apply to cosmetic packaging?
Not directly — EU 10/2011 is a food-contact regulation, and cosmetic packaging sits under separate rules. But most brand owners apply it anyway because it is the strictest well-documented benchmark, and retailers recognise it.
What is NIAS and why should I care?
Non-intentionally added substances: impurities, reaction by-products and degradation products that are present in the material without having been deliberately formulated in. A compliance exercise that only looks at the declared ingredients is incomplete, and recycled streams need the most attention here because the input is not fully characterised.
Can I test migration myself?
The testing itself needs an accredited laboratory — the methods are standards-based and the results need to hold up in an audit. What you can do in-house is the cheap screening that catches most problems early: odour, ash content, gel and black-speck counts, cross-cut adhesion, and compatibility storage testing with your own formula.
Next step
Send us your resin specification, target recycled percentage and destination market, and we will tell you which of the documents above we can issue per shipment and which we cannot — before you commit. See the full catalog or contact our team.