Most shipment delays for plastic consumer goods are not caused by the goods but by the paperwork that travels with them. This guide lists the documents a buyer should collect from the moulding side, and separates the legally required from the commercially expected.
REACH: SVHC communication is the obligation
REACH does not require a certificate for a moulded part. The obligation that reaches the supply chain is Article 33: if an article contains a candidate-list substance above 0.1 percent by weight, the supplier must communicate that to the recipient, and the information must flow down to the end user on request. In practice this means every article in a programme needs a written SVHC statement from the moulder, and the moulder needs the same statements from its resin and masterbatch suppliers. For large programmes, keep the statements per article rather than per shipment, and update them when the candidate list changes twice a year.
RoHS and the electrical items
Any product with a battery or a charging circuit falls under RoHS in the EU, which in this catalogue covers massager housings, remote control transmitters and similar items. The moulding plant contributes material declarations for the restricted substances; the finished-device CE marking and technical file belong to whoever puts the device on the market. Buyers importing finished devices should confirm who holds the technical file before the first shipment, because customs and market surveillance both ask for it.
Food contact declarations for export
Food contact items crossing a border need the material chain documented: resin grade statement, masterbatch declaration, and a declaration from the moulding plant covering machine dedication and release agents. The EU accepts this as a due-diligence pack under 1935/2004 and 10/2011; the US works through FDA 21 CFR with the importer of record carrying the responsibility. Migration testing of the finished article is a buyer-side test, commissioned at an accredited lab, and it is the document most often missing when a shipment is held.
| Document | Required by | Issued by | Scope |
|---|---|---|---|
| SVHC statement | REACH Art. 33 | Supplier, per article | Candidate list substances |
| RoHS declaration | EU RoHS directive | Supplier, per sub-part | Restricted substances in electrical items |
| Food contact pack | EU 1935/2004, FDA 21 CFR | Resin producer and moulder | Material and process chain |
| Migration test report | Buyer-side due diligence | Accredited lab | Finished article, per colour family |
| CE technical file | EU market surveillance | Device assembler | Electrical finished devices |
Commercial documents that are not legally required
Retail chains and marketplaces often ask for documents that go beyond the legal minimum: factory audit reports, social compliance statements, test reports per SKU and insurance certificates. None of these are customs documents, but they gate the purchase order. The practical advice is to collect them once per programme and reuse them, rather than per shipment, because the underlying facts do not change between orders.
Packaging and the dual-regulation trap
The packaging is regulated separately from the product. EU packaging rules cover heavy metal content and, increasingly, recycled content claims; a food contact claim does not transfer to the carton. Where a product is sold in a market with extended producer responsibility for packaging, the importer registers and reports, and the carton declaration should state the material composition so the report can be filed accurately.
Country-of-origin and valuation notes
Moulded parts shipped semi-finished still take their origin from where the moulding happened, which is usually what the buyer expects. The trap appears when a programme adds value later: parts moulded in one country and assembled in another can take origin from the assembly country under substantial-transformation rules, which changes the duty rate and the certificate requirement. Buyers routing semi-finished parts through a third country should confirm the origin outcome with their broker before the first shipment, because the paperwork cannot be corrected retrospectively at the destination.
Valuation raises the same question in reverse: customs value is the transaction value of the parts as sold, not the value of the finished product they become. A declaration pack that describes the parts as components with a stated material and process keeps the valuation defensible; one that describes them by their finished use invites a valuation review.
Related reading
Our child resistant closure programme ships with a full declaration pack, and the certification guides cover the product-side standards in detail.
Related product categories
The materials and part types discussed above are grouped in our sourcing directory:
