What Documents Do I Need to Import Plastic Bottles into the EU?
For plastic food-contact bottles: the resin declaration of compliance, a migration test report against EU 10/2011, and a statement of compliance for the finished article. Add RoHS if the pack has printing or electronic components.
The Three Documents
A declaration of compliance (DoC) from the resin supplier, a migration test report on the finished article against EU 10/2011, and a statement of compliance issued for the pack you are importing.
The DoC covers the material; the migration test covers the finished article; the statement ties them to your order.
What the Migration Test Actually Measures
Overall migration (the total mass that can transfer to food) and, where relevant, specific migration of monomers. It is run with food simulants — aqueous, acidic, fatty — matched to what the pack will hold.
What Is Often Missing
The declaration covers the resin lot, not the finished bottle, and it is rarely per shipment. Ask for the declaration with the order, and keep the lot number on file.
For recycled content, add the grade and percentage — mass balance is not the same as physical recycled content.
Where the Importer Sits
The importer is the responsible operator in the EU. The supplier provides the documentation; the importer holds it and can be asked for it by the authorities. That is why the documents are worth collecting before the container ships, not after.
The Two Documents That Matter
The EU 10/2011 declaration of conformity for the material, and the migration test report that supports it. Both are per grade, not per customer, and both should carry a laboratory name and a date.
For cosmetics, the packaging also needs a statement on heavy metals and, where relevant, recycled content.
Frequently Asked
What is EU 10/2011?
The EU regulation on plastic food-contact materials; it sets the migration limits the test report checks.
Do I need a migration test for every order?
Not for every order, but for the material and process combination; the declaration should cover the lot.
Is RoHS needed for bottles?
For printed or electronic packs, yes; for a plain bottle it is usually the printing inks that matter.
Who is responsible in the EU?
The importer is the responsible operator and must hold the documentation.
Do I need the originals?
A scanned signed copy is accepted by most importers; the original travels with the goods on request.
Who issues it?
The factory, on its letterhead, backed by the laboratory report.
Still Deciding?
Send the capacity, neck and quantity — we come back with a price, packing data and lead time within one business day.