After over a decade in PET packaging exports, I can say this with confidence: roughly 80% of customs delays have nothing to do with product quality. It’s the paperwork.
You find a supplier. The samples look great. You negotiate the price, place the order, and the shipment leaves. Then it hits the destination port — and sits there. Two weeks. You call the forwarder. Customs says “incomplete documentation.” At that point, there’s nothing you can do except pay the detention fees and wait.
The global PET packaging market reached $93.3 billion in 2026. Trade volumes are climbing, and regulators everywhere are getting more granular. Below is the complete documentation checklist — every item on it comes from real situations where our clients got burned. Take it seriously.
The Foundation Documents: Get One Wrong and Everything Stalls
1. Commercial Invoice
Looks easy, right? It’s actually the highest-error document in the stack.
Don’t just write “PET cans” and call it done. Customs needs: exact specification (milliliter capacity), container type (easy-open can vs. wide-mouth jar), lid type (aluminum lid vs. plastic lid), pieces per carton, unit price, total value, currency, and Incoterm (FOB, CIF, DDP). If any of these numbers don’t match what’s on other documents, it triggers a manual review — and that means delays.
HS codes deserve special attention. PET packaging generally falls under 3923.30 (bottles and similar articles) or 3923.90 (other containers). Different codes mean different duty rates. Get the classification wrong, and you’re looking at either back-duty payments or — in the worst case — return of goods.
2. Packing List
Number of cartons, carton dimensions, gross weight, net weight, what’s inside each carton (specification and quantity) — the customs broker cross-checks every line against the commercial invoice. A mismatch anywhere in the chain and the whole shipment gets flagged.
3. Certificate of Origin
Not every destination country requires one, but having it versus not having it can be the difference between paying full duty and getting a reduced rate under a free trade agreement. We typically issue through CCPIT — it carries strong international recognition.
The Food-Contact-Specific Documents
If your PET packaging is going to hold food or beverages, these documents are your non-negotiable paperwork trail:
4. Certificate of Compliance (CoC)
For the US market, this references FDA 21 CFR 177.1630. For the EU, it’s EU Regulation 10/2011 (overall migration limit of 10 mg/dm² for food contact). The CoC must cite the specific regulation number — a vague “complies with food safety standards” statement won’t cut it. Customs officers see generic language and immediately flag it.
5. Migration Test Report
Only reports from accredited labs count: SGS, Intertek, TÜV, or equivalent. These reports have a shelf life — typically one to two years depending on the destination country. An expired report is one of the most frustrating reasons for detention because the product itself is fine. We recommend annual renewal regardless, and immediate retesting any time you change resin suppliers.
6. Material Safety Data Sheet (MSDS)
PET is inherently safe, but shipping lines and customs authorities still want this on file. It’s primarily about transport safety classification, not food-contact risk.
7. Letter of Guaranty
The manufacturer puts their signature on the line, accepting legal responsibility for the compliance claims. In the US market, this document carries real legal weight — your supplier is accountable for what they certify.
Market-Specific Requirements That Changed in 2026
This year brought several regulatory shifts you need to know about:
| Market | Key 2026 Requirements |
|---|---|
| United States | FDA compliance + FSMA Rule 204 full-chain traceability + state-level add-ons (e.g., California Prop 65). GRAS notifications are now mandatory for food-contact materials. |
| European Union | EU 10/2011 + REACH registration + PPWR requires 25% recycled PET in beverage bottles, climbing to 30% by 2030 and 65% by 2040. Full PPWR enforcement started August 12, 2026. Also: as of June 2026, chemical recycling is now formally recognized in EU recycled-content calculations. |
| United Kingdom | UK REACH + post-Brexit independent labeling requirements |
| South Korea | Mandatory 10% rPET content in PET packaging, effective January 2026. This requirement is already live. |
| Australia / New Zealand | FSANZ compliance + AS/NZS recycling standards |
| Canada | Health Canada food-contact notification + bilingual labeling |
| Middle East | GSO standards; some countries require halal certification for food-contact materials |
What These Changes Actually Mean for You
The EU and South Korea both added mandatory rPET minimums in 2026. If you’re exporting to either market, it’s no longer enough to prove your material is food-safe — you also need to prove the recycled content percentage meets the threshold. That means chain-of-custody documentation for your rPET source, not just a claim on the label.
The EU formally recognized chemical recycling in June 2026. This is a big deal for suppliers working with high-grade recycled material. It opens a new compliance pathway — chemical recycling can now count toward PPWR recycled-content targets, which expands your sourcing options considerably.
US recycling infrastructure is contracting, not expanding. Seven of the thirty PET recycling facilities in the US have shut down. The domestic PET recycling rate now sits at roughly 25%. Here’s what that means for importers: demand for imported rPET and rPET-containing packaging is only going up. American brands need recycled content to meet their own sustainability commitments, and domestic supply isn’t keeping pace. rPET pricing reflects this — expect $0.65 to $0.90 per pound versus $0.55 to $0.75 for virgin PET.
The Five Most Common Mistakes We See
After years in this business, the same errors keep showing up:
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Winging the HS code. Someone thinks “close enough” and picks a generic code. Customs checks the product classification, finds it wrong, and the shipment goes into manual review. Hours turn into days.
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Invoice totals don’t match the packing list. Example: the commercial invoice says $50,000 total value, but quantity × unit price on the packing list works out to $47,000. Customs sees the discrepancy and suspects undervaluation. Now you’re explaining yourself instead of clearing your goods.
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Expired test reports. This one stings the most because the product is completely fine. Some countries require reports within 12 months, others allow 24. If your migration test was run in January 2024 and your shipment lands in July 2026, you’re probably holding an expired report.
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Missing food-contact documentation entirely. The container is obviously going to hold beverages, but it arrives with no CoC and no migration report. Customs doesn’t care how good your product looks — no documents means detention.
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Blurred Incoterms. FOB and CIF differ by three letters but several thousand dollars in freight and insurance liability. If you haven’t clearly defined who pays for what before the shipment leaves, you’re setting up a dispute.
How We Handle Export Documentation
CHINPK ships every export order with a complete documentation package — whether the customer asks for it or not:
- Commercial invoice and packing list (cross-checked line by line by our export team)
- CCPIT Certificate of Origin
- Food-contact CoC and current migration test report (renewed annually)
- Letter of Guaranty
- MSDS
- Destination-specific certificates tailored to your market
We send every document to the customer for review before the shipment leaves. Confirm first, ship second. Seventeen years, zero compliance violations — not because we’re lucky, but because the process is built to catch mistakes before they become customs problems.
If you’re planning a PET packaging import, or your current supplier keeps coming up short on documentation, reach out to us. We’ll map out your destination market’s requirements one by one. You can also browse our product range — PET cans, PET bottles, jars, each with market-matched compliance packages ready to ship.