Food contact materials · EU PPWR · Tobacco packaging · Pharmaceutical packaging · Medical device packaging · Cosmetic packaging · E-commerce packaging · Recyclability assessment · Material composition analysis
AT A GLANCE: One laboratory, nine packaging categories, one sample flow — from material screening and composition analysis through to the declaration of conformity your customer or customs officer asks for. | |||
Sectors covered | Accreditation | Group track record | Companies served |
9 packaging categories | CMA · CNAS | Nearly 20 years | 30,000+ |
1. Core services
Seven packaging categories under one roof — from the food contact article on the shelf to the export packaging that has to clear EU customs.
Category | Typical products | Core services |
|---|---|---|
Food contact materials | Films and pouches, food containers, beverage bottles, can interior coatings, paper cups and bowls, cap gaskets and sealing rings, single-use tableware, cutting boards; inks, adhesives, masterbatches | Domestic testing by material type under GB 4806; export testing under (EU) 10/2011, LFGB and FDA 21 CFR. Overall and specific migration; additive compliance verification. Sensory and performance: colour bleed, fluorescent substances, moisture content, volatile matter, odour, appearance. Containers: seal integrity, impact resistance, heat retention, coating adhesion. NIAS targeted quantification and non-targeted screening. |
Tobacco packaging materials | Tipping paper, carton and box wrapping paper, inner liner, water-based adhesives, acetate tow filter rods | YQ 57-2015, YQ 69-2015 and the YC/T series; solvent residues, phthalates, benzene, formaldehyde, photoinitiators, specific aromatic amines, heavy metals, D65 fluorescence brightness, colour fastness to saliva. |
Pharmaceutical packaging | Glass vials and ampoules, prefilled syringes, infusion bottles and bags, laminated films and aluminium foil, PVC/PVDC rigid films, rubber stoppers and caps | YBB series, Chinese Pharmacopoeia General Chapters 4000 series, USP <661>/<381>; physicochemical performance, container closure integrity, extractables and leachables, compatibility. |
Medical device packaging | Sterile barrier systems (Tyvek, medical-grade dialysis paper, coated paper, PE-PP film, aluminium-plastic pouches), paper-plastic pouches, FFS packaging, thermoformed trays | Seal strength and integrity, internal pressure and burst, dye penetration, microbial barrier, accelerated ageing and shelf-life verification. |
Cosmetic packaging | Plastic bottles and tubes, glass bottles, acrylic jars, compacts, lipstick cases, pumps and droppers, aerosol cans, metal components | Heavy metal migration, phthalates, solvent residues, azo colorants and aromatic amines, PAHs; leakage, drop test, appearance, inner-coating resistance to contents. |
E-commerce packaging | Courier envelopes, shipping boxes, electronic waybills, mailing bags, plastic cushioning, tape, reusable boxes and bags, FIBCs | GB 43352-2023, a mandatory national standard in force since 1 June 2024: non-compliant products may not be produced, sold or used. Separate limits for paper, plastics (non-degradable and biodegradable) and textile fibres; composite materials must comply material by material. |
Export packaging to the EU (PPWR) | All packaging placed on the EU market: transport, sales and grouped packaging | Applied in full since 12 August 2026. Recyclability must reach Class C (≥ 70%) from 1 January 2030 and Class B (≥ 80%) from 1 January 2038. Sum of four heavy metals ≤ 100 mg/kg; PFAS ≤ 25 ppb per substance, ≤ 250 ppb in total, total fluorine ≤ 50 ppm. Also covers recycled content, packaging minimisation, declaration of conformity and EPR registration. |
2. Material recyclability assessment
“Recyclable” is turning from a marketing claim into a market-entry condition. The EU PPWR has made it a three-tier A/B/C threshold: from 1 January 2030, packaging below Class C cannot be placed on the EU market at all.
China is moving in the same direction. GB/T 48042—2026, “Design evaluation for easy recycling and easy regeneration of plastic products — General principles”, was published on 30 July 2026 and will take effect on 1 February 2027 — the first national standard for “dual-easy” evaluation of plastic products.
In practice, most companies’ “recyclable” conclusion rests on one sentence from a supplier, or on a document-review self-assessment with no test data behind it. Our dual evidence chain pairs assessment with testing: the assessment sets the framework and the grade, the laboratory supplies measured data, every conclusion is labelled “document review” or “laboratory testing”, and the decision is stated under ILAC-G8 rules.
Grade | Recyclability rate (by weight) | Market access implication |
|---|---|---|
Class A | ≥ 95% | Highest grade, marketable over the full cycle |
Class B | ≥ 80% | Minimum requirement from 1 January 2038 |
Class C | ≥ 70% | Minimum requirement from 1 January 2030; phased out from 2038 |
Below Class C | < 70% | Not technically recyclable; prohibited from 1 January 2030 |
Deliverables. Recyclability rate by weight, recyclability performance class (A/B/C), EN 13430:2004 conformity statement, and improvement recommendations for each non-conformity.
3. Material composition analysis
Composition analysis identifies and quantifies unknown substances and unknown components, establishing composition and structure. Typical uses: verifying a supplier’s declared material, benchmarking a competitor product, investigating foreign matter and product failures, and reconstructing a formulation.
Direction | Objects | Methods and content |
|---|---|---|
Metal materials | Metal substrates and coatings, solder joints, fasteners, metallic foreign matter, metalworking fluids and surface-treatment agents, ores and metal minerals | Elemental composition and grade identification; ICP, EDX, AAS, AFS; foreign matter and precipitate profiling |
Non-metal materials | Plastics, rubber, coatings, adhesives, inks, additives, organic solvents, cleaning agents, paper-plastic laminates | Polymer identification and quantification, formulation reconstruction; FTIR, GC-MS, HPLC, Py-GC-MS; additive and adjuvant profiling |
The laboratory runs GC, GC-MS/MS, HPLC-MS/MS, ICP-MS, EDX, AAS/AFS, UV-Vis and FTIR instruments, and delivers a composition report together with improvement recommendations.
4. Other routine testing
Material identification by FTIR (GB/T 6040, ASTM E1252); polymer molecular weight and distribution by GPC; thermogravimetric analysis and thermal stability by TGA; elemental composition and foreign matter analysis by ICP, EDX, AAS and AFS; relative density; ash content; heat and cold resistance; stability testing.
5. Compatibility studies
Packaging stays in contact with its contents for months or years. Migration, sorption and chemical reaction can degrade the contents or create a safety risk. We recommend compatibility studies for the four packaging types below.
Packaging type | When a study is needed | Scope and deliverables |
|---|---|---|
Pharmaceutical packaging | Inhalation aerosols and sprays, injections and injectable suspensions, ophthalmic solutions and suspensions, nasal inhalation products and other high-risk dosage forms; risk-graded by route of administration | Extractables and leachables, sorption and migration assessment, accelerated and long-term stability; a compatibility report supporting the CDE associated review |
Medical device packaging | Sterile barrier systems in long-term contact with the device, where barrier performance after sterilisation and ageing has to be verified | Seal integrity before and after ageing, material-device interaction assessment, shelf-life verification |
Cosmetic packaging | Long-term contact between contents and bottle, pump or inner coating, where discolouration, odour or delamination may occur | Resistance to contents, appearance and odour change, inner-coating stability, assessed together with heavy metal migration and solvent residues |
Food contact packaging | Plastic, coated, rubber, paper and metal containers in long-term contact with food | Overall migration, specific migration and sensory assessment |
6. Non-intentionally added substances (NIAS)
NIAS are substances that are not intentionally added during the manufacture, processing, storage or use of food contact materials, but may still be present in the finished article. Their sources include impurities in raw materials, decomposition products and by-products formed during processing, environmental contaminants, and reaction products between inks, adhesives, coatings and substrates.
(EU) No 10/2011 defined NIAS for the first time; (EU) 2025/351 tightened source control and raw-material purity requirements. GB 4806.1 likewise requires companies to carry out a safety assessment of NIAS and to list, in the declaration of conformity, any substance that needs further assessment.
Our service covers targeted quantification (GC-MS, HS-GC-MS, LC-MS/MS, ICP), non-targeted screening with high-resolution mass spectrometry (HRMS), unknown-peak identification and confirmation, exposure assessment and TTC-based toxicological threshold grading — the evidence needed to support the NIAS clause of a declaration of conformity.
7. Why CIRS Testing
- One laboratory across every packaging material. Packaging spans paper, plastic, metal, glass and composites, and usually has to satisfy food contact, export, e-commerce and brand-owner requirements at the same time. One team, one sample flow, one report.
- Assessment plus testing. Laboratory measurement is layered onto the assessment framework, and every conclusion states whether it rests on document review or on measured data.
- Accreditation and equipment. CMA and CNAS accredited, with LC-MS/MS, GC-MS/MS, HPLC, ICP-MS, AAS, GC-FID and FTIR instruments in house.
- Backed by the CIRS Group. Nearly 20 years of compliance experience, offices in Ireland, the UK, the US, Korea and Japan, and in Shanghai, Beijing and Nanjing, and more than 30,000 companies served.
About CIRS Testing
CIRS Testing is the testing and compliance arm of the CIRS Group. Our packaging and materials laboratory provides testing, consulting and compliance assessment for food contact materials, pharmaceutical and medical device packaging, cosmetic packaging, e-commerce packaging and export packaging under the EU PPWR — supporting clients from material selection through to declaration of conformity.
Contact us
CIRS TESTING | A member of CIRS Group | CMA & CNAS dual-accredited laboratory Email: test@cirs-group.com | Website: www.cirs-testing.com/en |
Scan to reach our customer service team on WhatsApp. |
Note: This document is for informational purposes only and does not constitute legal advice.