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PFAS, CBAM And The Compliance Questions Buyers Are Asking Now

The compliance conversation has moved on from whether a bottle passes food contact. It now asks what is in it and where it came from, and both are documentation jobs.

PFAS, CBAM And The Compliance Questions Buyers Are Asking Now

Food-contact testing is no longer the hard part of importing drinkware. It is well understood, it has named standards, and a supplier either holds the reports or does not. What has changed is that buyers are now asking two further questions that a test report does not answer: whether a coating or a gasket contains a restricted substance family, and what the emissions behind the material are. Both are documentation rather than testing, and both are easier to answer at the enquiry stage than after a container has sailed.

The regimes, and what each one actually asks for

Five requests that look similar and are not
RegimeWhat it is aboutWhat it asks a buyer for
Food contact: FDA, LFGB and EU 1935/2004The materials that touch liquidTest reports for those materials, current and named to the article
PFAS restrictionsA family of chemicals used in some non-stick and stain-resistant treatmentsA declaration of whether the coating and the seals contain them, for the finished article
REACH SVHC and California Prop 65Substance screening and disclosureA current statement for this article, not a certificate carried over from a different one
Carbon border reportingEmbedded emissions in carbon-intensive goodsVerified figures for the material and the process, which is a supplier-side data exercise
Social audit: BSCI or SEDEXLabour standards at the siteA report whose scope names the site that actually makes your item

The pattern underneath all of them

Every one of these is a request for a document that names the article, the site and the market. That is the thread. A folder of certificates for products you do not sell and markets you do not ship to looks thorough and answers nothing, because a declaration is only as good as the article it names. The shortest way to fail a compliance review is to send more paper than the reviewer asked for and less of the paper that matches.

The two that catch buyers out

The declaration that is several products old. A material statement issued against an earlier version of a coating is worse than none, because it will be accepted and then contradicted. Ask for the issue to be tied to the article and the market.

The audit that covers a different building. A social-compliance report is only useful if its scope names the site where your item is made. Where a factory uses a partner for coating or print, the scope question becomes a real one.

What we hold, stated the way we state everything

This site publishes named standards rather than numbers: FDA food contact for the United States, LFGB against EU 1935/2004 for Europe, REACH SVHC and California Prop 65 for substance screening, an ISO 9001 quality management certificate, and third-party testing through SGS, TUV and Intertek where a market or a retailer requires a specific protocol. It does not publish certificate numbers or audit dates, because a figure scraped from a page is not a document you can file against an order. Ask, and it is issued against your article and your market.

Questions buyers ask

Should the compliance request go in the RFQ or after the quote?

In the RFQ. A requirement that arrives after the price is agreed becomes a change order, and one that arrives after production is a delay. The RFQ guide covers what else belongs in the same message.

Which market needs which document?

The four market rows on the quality page map the United States, the European Union, the United Kingdom and Japan and Korea to the standards that apply. Where your destination is not listed, ask rather than assume it works the same way.

Are these requirements the same for a promotional run?

The food-contact baseline is, because the article still touches a drink. The retail-specific packaging and labelling rules change, and that is where a promotional programme differs.

What documentation we hold for a given market is answered by a technical enquiry with the item and the destination in it. The supporting detail sits beside the control points on the QC checklist.

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