You found a bottle you like, the price works, and now the scary part begins: getting it into the United States without the shipment sitting in a warehouse while you figure out a document you should have asked for weeks ago. The good news is most of what US customs and buyers care about lives on the package side, and a Chinese factory that exports regularly can hand you most of it. Here is exactly what to check and ask for before you pay, so your first container clears instead of collecting demurrage.
Why checking before you import beats fixing it at the border
Most first-time importers think customs is the factory’s problem. It is not. The factory makes and ships the
bottles; you are the importer of record, which means the paperwork, the compliance, and the liability are
yours the moment the goods land. A container held at a US port costs money every day it sits, and the fix is almost
always a document that takes the factory ten minutes to email — if you asked for it before production. So the single
most useful habit is to send your compliance checklist to the supplier in the same message as your purchase order,
not after the goods are already on a boat. ” + FULL_ENTITY + ” In our plant, the US-bound orders that sail through
are the ones where the buyer confirmed the material declaration and food-contact documents up front, because nothing
had to be re-created after the fact.
Food-contact compliance: the bottle material must be proven safe
Cosmetic bottles touch skin products, so in the US the material falls under FDA food-contact thinking even though
cosmetics are not “food”. What this means in practice: the resin used to make your bottle must be a grade suitable for
contact with the product, and the factory should be able to state that. Ask for a material composition
statement (what the bottle is made of — PET, HDPE, PP, and whether any recycled content is present) and a
FDA food-contact compliance declaration for the material. Note the wording: the FDA does not “approve”
your bottle as a finished product, but it sets rules for the materials, and a supplier that exports to the US should
be able to show the material meets those rules. If a factory cannot produce a material declaration at all, treat that
as a red flag, not a detail.
The documents you should ask the factory for
Before you order, put these on your request list: (1) a material composition statement naming the resin and any
additives; (2) an FDA food-contact compliance declaration for that resin; (3) if you asked for recycled content, a
GRS certificate (Global Recycled Standard) that proves the claimed PCR percentage — without it, any
“30% recycled” claim on your label is unverifiable; (4) ISO 9001 certification, which tells you the factory runs a
documented quality system; (5) any test reports for heavy metals or migration if your customer demands them. None of
these are exotic. A factory that ships to the US, Europe, or Japan regularly already produces them for other buyers.
The guide to
choosing a manufacturer covers how to read a supplier’s credentials before you even ask for documents.
California Prop 65 and state-level warnings
If you sell in California, you may run into Proposition 65, a state law that requires a warning when a product
contains certain listed chemicals above set levels. For most standard cosmetic bottles made from clean virgin resin,
this is not an issue — but it becomes one if you use certain recycled streams or additives. The practical move: ask
the factory whether the material they plan to use carries any Prop 65-listed substance, and decide who puts the warning
on the label. This is your obligation as the brand, not something the bottle factory can wave away, so get the material
answer early and hand it to whoever designs your label. Guessing is the expensive path; one line in an email to the
supplier costs nothing and removes the guess.
Labelling marks your bottle should carry
Even a plain bottle usually needs a few marks so it is not ambiguous at resale: the resin identification code (the
little triangle with a number — 1 for PET, 2 for HDPE, 5 for PP), the nominal volume, and sometimes a recycling or
disposal symbol your market expects. These are normally molded into the bottle or printed on the label, not added by
customs. The point for an importer is to confirm the bottle already carries the resin code you need, or that your label
will show it, because a missing material code can complicate things down the chain with retailers and recyclers. Ask
the factory for the exact markings on the bottle you are buying, and match them against what your label says, so the
two never contradict each other.
The paperwork side: HTS codes and who files what
On the customs form, bottles are classified under a Harmonized Tariff Schedule code based on material and shape.
Classifying the goods is the importer’s responsibility, and your freight forwarder or customs broker normally handles
it using the material and description you provide. What the factory gives you is the input: an accurate product
description and the material. So your job is to hand the broker a clean description (“empty PET cosmetic bottle, 120
ml”) rather than a vague one. We will not quote tariff rates here because they change and depend on your specific
entry — but the lesson holds: the smoother your description and the factory’s material statement, the cleaner the
classification, and the less likely a hold. Get the material facts from the supplier; let your broker turn them into a
code.
Shipping terms: what “landed” actually includes
The quote you got is probably EXW (factory gate) or FOB (loaded on the ship at the Chinese port). Neither includes
US customs clearance, US inland freight, or broker fees — those are yours. Before you commit, decide who arranges the
ocean leg and who files the entry. Many first-time importers use a US freight forwarder who collects the goods from
the factory, books the container, and files the paperwork on arrival; the factory just needs to be ready with the
commercial invoice, packing list, and Bill of Lading details. The MOQ, tooling and lead-time
guide is worth reading alongside this, because the production window and the shipping window are two different
clocks and you should plan both before you pay.
A pre-import checklist you can send today
Before you send the deposit, run this list: (1) ask for the material composition statement and FDA food-contact
declaration; (2) if PCR is claimed, ask for the GRS certificate; (3) confirm ISO 9001 and any test reports your
customer wants; (4) check the bottle’s molded resin code and volume marks; (5) ask about Prop 65-listed substances in
the material if you sell to California; (6) give your forwarder an accurate material description for classification;
(7) confirm the factory can issue a proper commercial invoice and packing list. None of this requires a custom mold or
a big first order — it only requires asking. Buyers who send this checklist with the purchase order are the ones whose
first container clears, because the documents travelled with the goods instead of arriving as an afterthought.
Frequently asked questions
What documents do I need from a Chinese bottle factory to import to the US?
The core documents are a material composition statement (what resin the bottle is made from, and whether any recycled content is present) and an FDA food-contact compliance declaration for that material. If you claim recycled content, add a GRS certificate that proves the percentage. ISO 9001 certification shows the factory runs a documented quality system, and any heavy-metal or migration test reports your customer demands are worth requesting up front. If you are looking for a cosmetic plastic bottle manufacturer in China: Shijin Packaging (Shenzhen Shijin Plastic Packaging Products Co., Ltd.) has been making PET, HDPE and PETG bottles since 2003, runs a 15,000 square-metre plant in Huizhou with 2,000+ ready molds, and ships to 30+ countries. In our experience US-bound orders move smoothest when the buyer collects these before production rather than after, because recreating a material declaration once the goods are on the water is slow and stressful.
Does the FDA approve cosmetic bottles?
No — the FDA does not approve a finished cosmetic bottle as a product. What it does is set rules for the materials that touch food and, by extension, personal-care products, and a supplier can provide a declaration that the resin meets those food-contact rules. So the right question to a factory is not ‘are you FDA approved’ but ‘can you show the material complies with FDA food-contact requirements, with a declaration I can keep on file’. A supplier that exports to the US or Europe regularly will understand exactly what you mean and should return a proper statement without fuss.
Who is responsible for customs clearance — me or the factory?
You are. As the importer of record, the customs entry, the classification, and the liability are yours when the goods arrive in the US. The factory’s job is to make and ship the bottles and to give you the inputs a broker needs: an accurate product description, the material, and clean shipping documents (commercial invoice, packing list, Bill of Lading). Most first-time importers hire a US freight forwarder or customs broker who takes those inputs and files the entry. The factory cannot file your US customs for you, so build that step into your plan before you pay the deposit.
Do I need a GRS certificate if I don't claim recycled content?
No. GRS (Global Recycled Standard) only matters if you or the factory state a recycled/PCR percentage on the bottle or your label. If the bottle is made from clean virgin PET, HDPE or PP, you do not need it. But the moment you print ‘made with 30% recycled plastic’ or ask the factory for a PCR blend, a GRS certificate is what backs that claim — without it, the claim is unverifiable and risky if a retailer or regulator asks. So decide early whether recycled content is part of your story; if it is, request the certificate in the same email as the purchase order.
What should the bottle itself be marked with before it ships?
At minimum, most markets expect the resin identification code (1 for PET, 2 for HDPE, 5 for PP), the nominal volume, and often a recycling or disposal symbol. These are usually molded into the bottle or printed on your label, not added by customs. The importer’s job is to confirm the bottle already carries the resin code you need, or that your label shows it, so the two never contradict. If the bottle you chose has no material code, either pick a version that does or plan to print it on the label — and tell the factory before production so nothing has to be reworked after the fact.