Major Overhaul of Customs Inspection Regimes! Risk-Based Control Officially Implemented
Packaging Exporters to the EU: Watch Out for High-Risk Flags, Prepare CEPI & PTS Compliance Solutions in Advance
For a long time, many packaging exporters took chances, believing inspections depended purely on luck — getting selected during random sampling was just bad fortune.
However, inspection protocols at ports home and abroad are undergoing comprehensive transformation. The traditional equal-probability random sampling is gradually phased out, replaced by big-data-driven risk-based graded inspections.
Inspection odds are no longer uniform for all traders. The system automatically calculates risk scores based on enterprise profiles, cargo characteristics and compliance track records. High-risk entities are subject to targeted surveillance and frequent physical container inspections, while low-risk compliant companies enjoy expedited clearance via green channels.
This is especially critical for manufacturers of paper packaging, folding cartons, food packaging and composite packaging targeting the EU market. Combined with the official enforcement of the PPWR Regulation on 12 August, customs authorities both in exporting countries and the EU are tightening verification of packaging compliance.
Under the risk classification framework, the following six types of packaging enterprises will be flagged as high priority for inspection. Conduct self-inspection and rectification as soon as possible.
1. EU packaging exporters without CEPI / PTS test reports
Following PPWR enforcement, EU import customs and domestic departure ports have simultaneously strengthened pre-shipment checks. Key inspection items include aggregate limits for four heavy metals, PFAS, and hazardous substances present in inks and adhesives.
Many suppliers only deliver cartons without valid CEPI and PTS test reports, merely making verbal claims of “eco-friendly materials”.
⚠️ Risk Consequences:
Shipments will be automatically labelled high-risk by the system and are highly likely to undergo sampling testing upon arrival. Without valid test reports, goods face detention or return, incurring exorbitant port storage fees and compensation claims from buyers.
2. Packaging manufacturers with non-standard customs declarations
Common declaration errors:
- Vague commodity descriptions such as simply listing “cartons, paper boxes, packaging products”, without specifying paper grade, lamination status, food contact suitability, printing processes or coating materials;
- Arbitrary selection of overly general HS codes for convenience;
- Inconsistent material information stated across invoices, packing lists and bills of lading.
Risk mechanism:
Customs risk control AI cannot accurately identify packaging specifications, which immediately triggers manual review.
Enterprises repeatedly submitting incomplete declaration particulars will be permanently marked for attention, significantly raising inspection probabilities for all subsequent shipments.
3. Enterprises with prior export compliance violations
Records retained within customs systems will affect risk ratings over the long term:
✅ Typical historical violations include:
- Wooden packaging lacking valid IPPC marks or supported by fraudulent fumigation certificates;
- Missing packaging markings and non-compliant origin labelling;
- Detected excessive heavy metals in inks and misdeclaration of packaging materials;
- Infringing printing and counterfeit graphic designs.
Important reminder: Compliance records accumulate dynamically and will not be cleared automatically.
Frequent inspection anomalies within a short period will push an enterprise into a higher risk tier and place it on a permanent watchlist.
4. Manufacturers of laminated, composite and specially coated packaging
Paper-plastic composites, coated paper, oil-resistant cartons and multi-layer composite packaging are heavily regulated under global environmental legislation.
Regulators focus on two core issues:
- 1. Composite structures are difficult to recycle and may fail to satisfy EU recyclability requirements;
- 2. Coatings and oil-repellent additives often test positive for PFAS persistent chemicals.
Numerous small and medium printing factories source coating films and adhesives from external suppliers without complete upstream material documentation to trace chemical composition. Once selected for laboratory testing, non-compliance is highly probable. Such goods have seen frequent detention at overseas ports recently.
5. OEM factories handling scattered cross-border e-commerce orders
Typical traits: fragmented orders with frequently changing buyers, mostly producing for cross-border sellers and small traders. Factories only focus on printing and production without proactively confirming compliance requirements for destination markets.
Three prominent hidden risks:
1. Packaging carries environmental claims such as “biodegradable”, “eco-friendly” or “100% recyclable” without supporting test documentation; false green claims face rigorous crackdowns.
- 2. Last-minute graphic revisions by clients raise trademark and intellectual property risks.
- 3. Low-cost bulk folding cartons generally utilise inexpensive inks with unstable heavy metal levels.
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6. Manufacturers supplying matching wooden packaging
Although wooden packaging falls outside the scope of paper packaging, most carton factories ship goods alongside wooden pallets.
Key inspection focus areas: counterfeit or blurry IPPC marks, incomplete heat treatment certification, and mixed new and used timber that has not undergone re-treatment.
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